1. PRIVACY POLICY

The following document governs and details the Privacy Policy of SysVPN which is the Android, iOS, Mac and Windows-based online Virtual Private Network (“VPN”) application through which we are offering our services. At our application and website, the privacy of all of our users, customers, clients and buyers is protected and respected. This privacy statement is drafted in order to declare our website’s data protection and data collection practices by explaining specifically how we protect users’ data, and what measures have been taken in order to be in compliance with different local and global privacy laws. This policy is written for all the users, clients, buyers and customers (herein collectively will be called “users”) to understand how our website and application (“we”, “our”, “SysVPN”) use, collects, share, and protect users’ information and data. We request our users to read this privacy policy statement before using our VPN application and services. The users of our application and our services will be assumed to be in agreement with our privacy statement after we have published this Privacy Policy on and/or through our application and website.

2. COLLECTION OF DATA

Our website and application collect information that is necessary for the purpose of delivering our services. Personal information includes (but is not limited to) e-mail address of the user. The information which will be collected in this process will be used to provide services to the user as well as in order to communicate with that user through e-mail and/or newsletters. Some information on our application/platform will be gathered automatically through different tools and plugins.

2.1. Users Information Collection.

There will be a collection of information from all of our users when they create an account on the SysVPN website and/or application if they will use any of our given services. The information that will be provided to us includes but is not limited to:

• Email address
• Users' Third-Party Related Information (Collected Automatically)
• Payment Information (Processed Automatically)
• Any additional information relating to the users that they provide us directly through our application or indirectly through our platform or online presence such as ‘cookies’.

2.2. Payment Information

Our users can be subscribed through our website or through the relevant application store they have used to download the app. Additionally, users can also use our website for subscription purposes. The payment information will be processed automatically by the application stores and the payment gateways that have been implemented by these relevant application stores payment gateways. The same application stores will treat and safeguard the users’ data with security measures they have implemented. In order to know about the data protection policies, all users are requested to view and read the privacy policies of Apple, Microsoft and Google.

2.3. Automatic Information Collection

We also collect information that is collected by general websites and mobile applications for the purpose of rendering normal services. This type of information includes (but is not limited to) application usage by users, referring nodes, device OS and its type, language and its preference, and data and time of users’ browsing history. We may release such information in aggregate form for the purpose of making our services better. Please note that in aggregate form none of the individual users can be identified. Our services may also collect information that is considered personal identifiable information such as IP addresses and other information collected through cookies.

3. USE OF COOKIES

Our website uses, collects, and stores cookies on users’ devices. This cookie policy is written according to the privacy rights and user rights policies and we are letting our users know that their data may be collected and they can contact us if they want to have their data removed. A cookie is a log file that collects certain information and is stored on the user's or visitor’s device or personal computer. This information will be provided back to the device if such a user or visitor makes a return visit. The most common types of cookies are session cookies and permanent cookies. Session cookies are temporary cookies that are deleted once the user exits the browser while permanent cookies remain in the user’s or visitor’s browser until the cookie log files are either deleted by the user or expired on their own. Mainly we use cookies in order to (i) understand how visitors are arriving at our application; (ii) in order to monitor the usage of our mobile application; (iii) remember when a user last visited our application and if the cookie persists continuing that user’s usage from the last time; (iv) in order to keep track for analysis we may store analytical cookies; (v) track for the purpose of marketing; (vi) for error reporting; (vii) for customer services; (viii) to conduct research and development by gathering user data in aggregated form. A functional cookie is a type of permanent cookie that is necessary for the purpose of some services.

4. THIRD-PARTY LINKS

We rely on third-party platforms in order to render our services. Please note that all of these services are changeable and we may use other alternatives in case we find new, better, and improved third-party platforms. There might also be a presence of third-party tracking and analytical services links on our application that may also include the services of Google Analytics which may help us track users’ session activity, bounce rate, time of stay, and general traffic analytics. Most of these links will only be there in order to help us provide our services. Please note any links that are on or through our application are there either for marketing purposes or for other services as a requirement for the working of our application. These links may or may not be associated or affiliated with us in any way.

5. PROTECTION AND SHARING OF CONSUMERS AND USERS' DATA

We are committed to protecting the personal data of consumers and users to the best of our ability. Data security is necessary and therefore in compliance with the global data privacy laws we have implemented measures in order to make sure that all data belonging to the consumers and users of our application is well protected. We have made sure that all the transactions on and through our application are going through well-protected payment platforms. Our application neither collects any payment-related information nor do we control it.

We May Share Users’ Information In Following Instances:

• When we are required by a court of law or legal authority to do so.
• When our business is transferred or sold to a new company or owner and in that transaction, the data stored by us will also be transferred to the new owner.
• We may store and transfer the personal data of the users out of their residential countries including out of the European Union regions in order to store and process our data. This step will be taken in order to make our services better. Users of our application hereby acknowledge that their data can be stored on hosting servers that are outside their residential jurisdiction.
• We will share the users’ data with our service providers (such as web-hosting providers, payment partners, etc.), affiliates, marketing partners, business partners, and others who have legal rights to access users’ data.

6. PRIVACY AND GDPR USER RIGHTS

In compliance with the GDPR, this statement has been provided for all the users of our application who are using any or all of our services. All users have the right to access their personal information and they have the right to know how their data is being stored on our application. Users can also have their data removed or transferred from our application.

Users have the following rights.

• The right to access.
• The right to rectification.
• The right to erasure
• The right to restrict processing.
• The right to object to processing.
• The right to data portability.

If any user makes a request, we have one month to respond to the user. If anyone would like to exercise any of these rights, please contact us at this email: [email protected].

7. NOTICE FOR RESIDENTS IN THE EUROPEAN ECONOMIC AREA REGARDING STORAGE OF DATA

All information users provide to us is stored securely and treated with care and respect. The data that we collect from users may be transferred to and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by persons operating outside the EEA. If we do send users’ data outside the EEA, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect users’ information.

8. CCPA COMPLIANCE

The California Consumer Privacy Act (CCPA) is an act enacted for the residents of the USA and specifically for the residents of the state of California. This law provides additional protections and rights for the protection of personal information for California residents. Our website does not sell personal information for monetary consideration; however, we do work with and share personal information with certain partners and third parties unless otherwise stated in this Privacy Policy. Under CCPA, users hold certain rights that apply to the collection, storing, and sharing of their personal information. Users can contact us to exercise their rights under CCPA by emailing us at the address below.

Under CCPA users have the following rights.

• Users have the right to know what personal information our website collects.
• Users have the right to know who we share their data with.
• Users have the right to delete their data.
• Users have the right to receive Non-Discrimination services.

8.1. PRIVACY OF CHILDREN AND PARENTS ACCOUNTS IN COMPLIANCE WITH COPPA

COPPA means The Children’s Online Privacy Protection Act. This act was enacted in 1998 and under this act, all the measures have been made to protect the information of children, specifically children under 13. The main focus of the COPPA act is to put parents in control of the information that their children may be having access to. Our website and app do not knowingly collect information from children who are under 13 years of age. And we do not knowingly collect, store, maintain, or use personally identifiable information from kids or children under age 13. If you are under 13, you should never provide us with any personal information, nor should you be using our website and our services.

8.2. Privacy Notice Disclosure For Parents Regarding Services Usage By Kids Under 13

We support the Children's Online Privacy Protection Act (“COPPA”) and other frameworks like the General Data Protection Regulation (“GDPR”). Our goal is to minimize the information gathered from and disseminated about Children while permitting them active participation in the trustworthy information, education, and independent voice for which we are known.

In order for your kid to use the SysVPN website and services, he/she will require your permission to use our app and services. Along with that, we will be requiring the parent’s email, which we use to ask for that parent’s consent.

How May Parents Access, Change or Delete Information About Their Kids?

• If you are a parent, and we need your consent to certain processing of your kids’ personal information if you:
  • wish us to cease further collection of personal information from your Children;
  • wish us to make no further use of, or delete, the personal information we have collected online from your Children; and/or
  • no longer wish for your children to participate as the user of our services.
• we will delete your Child’s Profile, and any parental contact information we may hold, upon request.

Note: We will be needing the same e-mail account and confirmation from that e-mail that was used to create your kids’ account on our website and application. This step has been taken to improve the security of our services.

9. REASONS FOR USERS’ INFORMATION COLLECTION

Unless otherwise stated, information is collected for internal purposes only which include the following:

• Administering services provided by our website and application, including informing users of any relevant information contained within our website.
• Improving productivity of our website.
• Contacting the user for the purpose of research, product development or changes, and customer service.
• Compiling anonymous statistical data and analysis for use internally or with third parties.
• Creating and managing accounts.
• Delivering tailored advertising, news, or other promotional material from the website to the user.
• Enabling communication between the website and the user.
• Sharing user information with new partners in the process of selling, expanding, reducing, or acquiring new business and assets.
• Fulfilling and managing purchases, orders and payments, refunds, and other transactions relating to the website.
• Increasing the efficiency and operation of our website.
• Offering new services, and recommendations, and requesting customer feedback.
• Performing other necessary business activities.
• Preventing fraudulent transactions, monitoring against theft, and protecting against criminal activity.
• Resolving disputes, troubleshooting problems, and responding to product and customer service requests.

10. OPT-OUT RIGHT FROM E-MAIL LIST

All users have the right to opt-out of our e-mail list by removing themselves from our e-mail list. Users can either e-mail us at [email protected] if they wish to stop receiving our e-mails or they can also follow the “unsubscribe link” provided at the end of every email

11. MODIFICATIONS AND AMENDMENTS IN PRIVACY POLICY

Any amendments or modifications in this Privacy Policy will be made based on the requirements and necessities of our application. All updated information will be publicly displayed on this page.

12. CONTACT

Any questions, remarks, queries, and feedback regarding any of the above-mentioned terms of our Privacy Policy can be directed at [email protected].