PROVPN Software License and Privacy Policy
Last Modified: May 01, 2020, Effective May 01, 2020
This Software License and Terms of Service Agreement (the "Agreement") for the PROVPN, the website at
provpn-ios.com,
and all other online properties and websites owned or operated by PROVPN is a legal contract between the individual accepting and agreeing to
this Agreement ("you") and PROVPN.
1.We Do Not Identify You
At PROVPN, we stand behind our commitment to user
privacy and security. When you access our websites and use our
best-in-class VPN products, you'll share some information with us, which
we use to provide and improve our products, send notifications and
updates, troubleshoot, and to support our free product through
advertising. Our goal is to be upfront about what we collect, how we use
it and whom we share it with, and that’s why we've written this Privacy
Policy. This Privacy Policy also tells you about your rights and
choices with respect to your information, and how you can contact us if
you have any questions or concerns. Below is a snapshot of some of our
important privacy practices, but please read the full Policy for more
detail. If you have any questions about anything in this Policy, please
feel free to reach out to us at
[email protected].
2.Privacy Overview
Our VPN product will never store or log your IP
address beyond the duration of your VPN session, and we always delete
your IP address after you disconnect from the VPN.
We do not keep logs of your online activities
and never associate any domains, or applications that you access while
the PROVPN is connected with you, your device, or your email.
Creating an account is always optional - we never
require you to register or otherwise provide us any contact information
to download or use our products While we always de-identify your IP
address while connected to the VPN. Remember that no VPN provider can
control what other apps collect from your device or what cookies other
websites or third parties place in your browser. For more information
about how to exercise choices with respect to certain third party
cookies, please see the Third Party Advertising section below.
3. Security Overview
When the PROVPN is connected, we encrypt all of the
traffic between your device and our servers, using different secure
algorithms. Your web traffic on unsecured networks such as public Wi-Fi
at cafes, airports, etc. is always securely encrypted when the PROVPN
is connected.
4.What Does This Privacy Policy Cover?
This Privacy Policy covers the free and paid versions of
PROVPN including the mobile and desktop applications, as well as the
our websites, (collectively, the “Services”). The terms “PROVPN”,
“We”, “Us” and “Our” include PROVPN, and our affiliates and
subsidiaries. By using the Services, you agree to the terms and
conditions of this Privacy Policy. Beyond the Privacy Policy, your use
of the Services is also subject to our Terms of Service. Separate from
our consumer applications, PROVPN licenses its technology to third
party partners for integration with their applications. This Privacy
Policy may also apply to our partner applications. However, this Privacy
Policy does not apply to the extent that We only process Personal
Information on behalf of our partners as part of third party partner
products. To learn more about the processing of your Personal
Information in that context, please refer to the relevant partner's
privacy policy.
5.What Personal Information Do We Collect?
For the purpose of this Privacy Policy. ”Personal
Information” means any information relating to an identified or
identifiable individual. We obtain Personal Information relating to you
from various sources described below. Where applicable, we indicate
whether and why you must provide us with your Personal Information, as
well as the consequences of failing to do so. If you do not provide
Personal Information When requested, you may not be able to benefit from
some features of our Services if that information is necessary to
provide you with that feature of our Services. There are two basic
categories of Personal Information we collect:
Personal Information you choose to give us
Personal Information we automatically collect When you use our Services
You can be assured that the Personal Information We may
collect, including your email, IP address, username, or unique mobile ID
is never associated with any online activities you engage in while the
PROVPN is connected. Additionally, when the PROVPN is connected,
your IP address is stored in encrypted format for the duration of the
session and is deleted after you disconnect from the VPN.
6. Personal Information You Choose To Give Us
When you interact with our Services, we collect the
Personal Information that you choose to share with us. For example, if
you purchase a subscription to PROVPN's premium plans, and/or sign up
to create an account, you may provide us with an email address and
payment information. Remember that creating an account is always
optional - we never require you to register or otherwise provide us any
account-related information to download or use our products.
Additionally, if you make a payment using a credit or debit card through
the Services, your Personal Information will be collected by a
third-party payment provider and not by us. If you make a payment via
PayPal, or in the Apple App Store or Google Play Store, payments are
processed by those third parties, and will be subject to the third
party's privacy policy, rather than this Privacy Policy. It probably
goes without saying, but well say it anyway. If you contact us directly,
we may receive additional Personal Information about you. For example,
when you contact customer support, we receive the contents of messages
or attachments that you send to us, and other information you choose to
provide.
7. Personal Information We Collect Automatically When You Use The Services
When you download the PROVPN app, connect to the PROVPN, or visit our websites, we and our third party service providers
collect information about you or your device automatically. Here's a
fuller explanation of the types of Personal Information collected when
you use our Services:
When you launch the PROVPN app, before you
connect to the VPN, we and our service providers collect device-specific
information, such as the unique mobile ID, hardware model, operating
system version, language, and network information. We may also use, but
never log or store, your IP address to derive your approximate
(city-level) location. We use this information to provide and improve
the Services, troubleshoot and perform analytics on our services. Our
service providers may collect IP addresses for marketing attribution
purposes.
When you connect to the PROVPN, we collect
your IP address, immediately encrypt it and store it only for the
duration of your VPN session. Your IP address is deleted after you
disconnect from the VPN. We do not associate your IP address with your
online activities and we do not store or log your IP address after you
disconnect from the VPN.
We do not attribute any specific website visits
or app usage to any specific user. We do not keep logs of your online
activities and never associate any domains or applications that you use
with you, your device, or email. Websites visited via our servers are
aggregated and stored to: (1) Perform analytics on our services,
including measuring whether our users, in aggregate, are able to
successfully access certain websites or apps; (2) Troubleshoot service
issues and improve service quality.
8. When You Visit Our Websites
We and our third party service providers and
partners (e.g. Google Analytics, Maxmind) may automatically collect
information from your device, sometimes by placing cookies, beacons, and
similar technologies in your browser and on emails that we send you. We
may use this information, for example, to ensure that the website
functions properly, to determine how many users have visited certain
pages or opened messages or newsletters, or to prevent fraud. If you do
not want information collected through the use of cookies, there is a
simple procedure in most browsers that allows you to automatically
decline cookies or be given the choice of declining or accepting the
transfer to your computer of a particular cookie (or cookies) from a
particular site. You may also wish to refer to
www.allaboutcookies.org/manage-cookies/index.html. Keep in mind though,
if you do not accept cookies, you may experience some inconvenience in
your use of the website. To find out more about how to exercise choices
with respect to certain third party cookies, including opting out of
receiving such cookies, visit the Digital Advertising Alliance's
Self-Regulatory Program for Online Behavioral Advertising at
www.aboutads.info, or the Network Advertising Initiative at
www.networkadvertising.org.
Your IP address may be collected when you visit
our websites, but is not stored beyond your visit to our website. We may
use your IP address to derive your approximate (city-level) location.
Again, we delete the IP address after you leave our website. Please see
the "When you use PROVPN" section above to learn more about how we
treat your IP address when you use our VPN products.
When you visit our websites, we may collect
device-specific information, such as the unique mobile ID, hardware
model, operating system version, browser type, language, internet
service providers and mobile network names. We only use it to provide
and improve the website, troubleshoot, and perform analytics.
Our websites also use Google Analytics and
Google Tag Manager which use cookies and similar technologies to collect
and analyze information about use of the Services and report on
activities and trends. You can learn about Google's practices by going
to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout
Information collected when you visit our website
is in no way associated with your online usage when you're connected to
our VPN products.
9. Third Party Advertising
Our paid PROVPN Premium version has no ads. However,
for users that choose to use our products for free, We are proud to
offer a free, advertising-supported version of PROVPN. On the free
version of PROVPN you may see some generic ads that our ad partners
place. PROVPN does not share your browsing history or any other
information you choose to provide, with advertisers. Furthermore, when
the VPN is connected, PROVPN anonymizes your IP address, thus showing
advertisers the IP address of PROVPN servers instead of your IP
address. We may share your general (city level) location. Additionally,
advertisers may be able to collect certain information independently
from you or your device when serving ads from the PROVPN application,
including your device's advertising ID, IMEI. MAC address, and wireless
carrier. Keep in mind that advertisers may be able to access your IP
address if your device is not connected to the PROVPN. For more
information regarding your device's advertising ID and its options,
please visit
https://support.google.com/googleplay/answer/3405269 for Android devices or
https://support.apple.com/en-us/HT202074
for iOS devices. If you use PROVPN Premium, the premium subscription
based version of our product, we will not serve any ads and thus no
information will be collected by our third party ad partners on the
Premium product.
10. How Do We Use Your Personal Information?
In short, we use your Personal Information to provide
you with amazing products and services that we are constantly working to
improve. Here are some of the ways we do that:
To operate, maintain, enhance and provide
features of the Services, provide services and information that you
request, respond to comments and questions, and otherwise provide
support to users.
Understand and analyze aggregate usage trends,
improve the Services, and develop new products, services, features, and
functionality.
Contact you for administrative and informational
purposes. This may include providing customer service or sending
communications, including changes to our terms, conditions, and
policies.
For marketing purposes, such as sending marketing messages, or campaign attribution and optimization for user acquisition.
For our business purposes, such as audits, security, fraud monitoring and prevention.
To enforce our Terms of Service or other legal rights.
If you are located in the European Economic Area, we
only process your Personal Information based on a valid legal ground,
including:
When we need your Personal Information to
provide our services, including for account registration, to respond to
your inquiries, or for customer support;
We have a legal obligation to use your Personal Information (such as to enforce our terms and conditions);
When we or a third party have a legitimate
interest in using your Personal Information. In particular, we have a
legitimate interest in using your Personal Information to troubleshoot
issues, perform product improvement conduct business analytics, conduct
and optimize user acquisition, serve non-personalized ads, and otherwise
monitor and improve the safety, security, and performance of our
Service. We only rely on our or a third party's legitimate interests to
process your Personal Information when these interests are not
overridden by your rights and interests;
If you otherwise consent to the processing of your Personal Information.
11. How Do We Share Your Personal Information?
We only share your Personal Information as described in
this privacy policy in order to provide and improve the Services,
facilitate a merger or sale of our business, or if required to do so by
law. As stated above, we do not log your browsing data and we delete
your IP address when you disconnect from the VPN. Here are some more
specifics on whom we share your information with and why:
To our third party service providers who provide
services such as website hosting, payment processing, data analysis,
information technology and related infrastructure provision, customer
service, email delivery, fraud prevention, online advertising, auditing,
and other services.
When you launch the PROVPN app, we may also
use your IP address, which we automatically delete after you disconnect
from the VPN, to derive your approximate (city-level) location. When you
are connected to the PROVPN, advertisers are prevented from seeing
your IP address, however if you are using the free version of PROVPN
we may share this approximate (city-level) location. If you are using
the premium PROVPN Premium version this approximate city- level
location will not be collected and will not be shared.
To a potential or actual acquirer, successor, or
assignee as part of any reorganization, merger, sale, joint venture,
assignment, transfer or other disposition of all or any portion of our
business, assets or stock (including in bankruptcy or similar
proceedings).
Again, we do not require you to provide us with
any contact information in order to download or use our VPN product, we
do not log or store your IP address after you disconnect from the VPN,
and we do not keep logs on your online activities. Therefore, we
generally do not have Personal Information to share with law enforcement
and generally do not have the data to provide in response to law
enforcement requests. You can read our Transparency Report for more
information on our responses to laW enforcement requests.
However, we may share what Personal Information
we do have if required to do so by law or in the good faith belief that
such action is appropriate: (a) under applicable law, including laws
outside your country of residence; (b) to comply with legal process; ©
to respond to requests from public and government authorities, including
public and government authorities outside your country of residence;
(d) to enforce our terms and conditions; (e) to protect our operations
or those of any of our affiliates; (f) to protect our nghts, privacy,
safety or property, and/or that of our affiliates, you or others; and
(g) to allow us to pursue available remedies or limit the damages that
we may sustain.
If you use the Premium version of PROVPN no
information is shared with advertisers. We may use and disclose
aggregate information that does not identify or otherwise relate to an
individual for any purpose, unless We are prohibited from doing so under
applicable law.
12. Third Party Services
This Privacy Policy applies only to the processing of
your Personal Information by PROVPN. You may see third-party links or
integrations on the Services. Keep in mind that this Privacy Policy does
not address, and We are not responsible for, the privacy, information
or other practices of any third parties, including any third party
operating any site or service to which the Services link. The inclusion
of a link on the Services does not imply endorsement of the linked site
or service by us or by our affiliates.
13. Security
Turning the PROVPN on encrypts all of the traffic
between your device and our servers using TLS1.2 with perfect forward
secrecy (ECDHE). 128-brt/256-bit AES data encryption, and HMAC message
authentication. This means that your web traffic on unsecured networks
such as public Wi Fi at cafes, airports, etc. will be securely encrypted
by PROVPN. This encryption also means that your Internet Service
Provider (ISP) will not be able to snoop on your web traffic and create
records of the websites you are visiting while the PROVPN is
connected; all they will see is that all of your traffic is being sent
to and from our servers. We also maintain administrative, technical and
physical safeguards that are intended to appropriately protect Personal
Information against accidental or unlawful destruction, accidental loss,
unauthorized alteration, unauthorized disclosure or access, misuse, and
any other unlawful form of processing of the Personal Information in
our possession.
14. Data Retention
As stated above, we do not retain your IP address beyond
your VPN session and do not log your online activities. We take
measures to delete your Personal Information or keep it in a form that
does not allow you to be identified when this information is no longer
necessary for the purposes for which we process it, unless we are
required by law to keep this information for a longer period. When
determining the retention period, we take into account vanous criteria,
such as the type of products and services requested by or provided to
you, the nature and length of our relationship with you, possible
reenrollment with our products or services, the impact on the services
we provide to you if we delete some information from or about you,
mandatory retention periods provided by law and the statute of
limitations.
15. Your Rights And Choices
Marketing Communications. We do not require that you
provide us with your email or any contact information to use our
Services. But if you do provide us an email, from time to time you may
receive marketing email messages from us consistent with your choices.
If you no longer want to receive such emails from us on a going forward
basis, you may opt-out via the "unsubscribe" link provided in each such
email. Please be aware that, even after you opt out from receiving
commercial messages from us, you may continue to receive necessary
administrative messages regarding the Services. Your Data Protection
Rights (EEA). If you are located in the EEA, you have the right to
request access and receive information about the Personal Information we
maintain about you, to update and correct inaccuracies in your Personal
Information, to restrict or object to the processing of your Personal
Information, to have the information blocked, anonymized or deleted, as
appropriate, or to exercise your right to data portability to easily
transfer your Personal Information to another company. Those rights may
be limited in some circumstances by local law requirements. In addition
to the above-mentioned rights, you also have the right to lodge a
complaint with a competent supervisory authority subject to applicable
law. Where required by law, we obtain your consent for the processing of
certain Personal Information collected by cookies or similar
technologies, or used to send you direct marketing communications, or
when we carry out other processing activities for which consent may be
required. If we rely on consent for the processing of your Personal
Information, you have the right to withdraw it at any time and free of
charge. When you do so, this will not affect the lawfulness of the
processing before your consent withdrawal. To update your preferences,
ask us to remove your information from our mailing lists, delete your
account or submit a request to exercise your rights under applicable
law. please contact us as specified in the "Contact Us" section below.
16. Use Of Services By Minors
The Services are not directed to individuals under the
age of sixteen (16), and we request that they not provide personal
information through the Services. If we find out that a child under 16
has provided personal information, we will take steps to delete that
information.
17. International Cross-Border Data Transfer
PROVPN uses servers hosted in the United States.
Please note that we may be transferring your information outside of your
region for storage and processing in the United States and around the
globe. By using the Services you consent to the transfer of information
to countries outside of your country of residence, including the United
States, which may have data protection rules that are different from
those of your country. If you are located in the EEA, we comply with EU
data protection law when transferring your Personal Information outside
of the EEA, including to the United States where We are headquartered.
To protect Personal Information transferred from the EEA or Switzerland
to the U.S., we are certified to the EU-U.S. and Swiss-U.S. Privacy
Shield frameworks.
18. Updates To This Privacy Policy
We may make changes to this Privacy Policy. The “Last
Updated” date at the top of this page indicates when this Privacy Policy
was last revised. If we make material changes, we may notify you
through the Services or by sending you an email or other communications.
We encourage you to read this Privacy Policy periodically to stay
up-to- date about our policy practices. Your use of the Services
following these changes means that you accept the revised Privacy
Policy.
19. Contact Us
If you have any questions about this Privacy Policy, please contact us at
[email protected] If you would like to exercise your rights to your Personal Information, please contact our support at
[email protected]