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Privacy Policy

Last updated: 26 October 2020


This privacy policy (“Privacy Policy”) sets forth the privacy practices of PrivateVPN Global AB, reg. no.  559282-2182 (collectively, “we”, “us”, “our”, or “PrivateVPN”) and applies to users (“user” or “you”) of PrivateVPN’s services, including, inter alia, the PrivateVPN VPN service (“Service”) and PrivateVPN website at https://privatevpn.com (the “Site”).


Your privacy is important to us. Whether you are browsing our Site or using our Services we want you to understand what information we collect about you and how this information is used. Our main principle is to collect only the minimal data required to provide our Service and for our users to remain as anonymous as possible. It is therefore our policy to not log or store any unnecessary data about our users. Hence, we do not collect or store logs of your activity, including no logging of browsing history, traffic destination, connection time stamps, DNS queries, IP addresses (neither allocated IP nor connected IP), data content or bandwidth.


By using our Services or browsing our Site, you are indicating that you accept the Privacy Policy and terms and conditions and that you agree to abide by them. If you do not agree to them, please refrain from using our Services and/or Site.


We also recommend that you read our terms and conditions before you start using our Service since both these documents together will give you a full understanding about information and liabilities. The terms and conditions are available on the Site. All definitions and capitalized words used in this Privacy Policy are defined here or in our terms and conditions.  


Information we collect


PrivateVPN does not collect or log any traffic or use of the Service. If you are browsing our Site, you do not have to give us any identifiable information. We do not track any activities outside of our Site. For more information about browsing our Site, see the “Cookies” section below. The following section describes what information that we collect from you, i.e. what personal data we are using. Please note that you might submit more personal data to us without it being a request from us, e.g. when asking questions in our online chat or otherwise communicating with us.


Information related to you and your account


To be able to use our Service you need to register an account at our Site. To register an account, you need to provide us with an e-mail address and a password. The e-mail address is your username.


Payment information


All payments are made through Paypal, Bitcoin or Stripe. These payment processing partners process basic billing information for payment processing and refund requests, such as date of purchase, payer’s IP address, zip code, full name and credit card information. We refer to the respective processor’s privacy policy and terms of use for further information about what kind of information they might collect. PrivateVPN can access this data from the payment processing partners but will not do so unless necessary, such as in cases of refund requests and when compiling sales statistics for accounting purposes.


Purpose and legal basis


The personal data we collect about you when using our Service is used to create your account after registration and thereafter for the purpose of the performance of the contract with you. We also use the personal data to identify and communicate with you primarily for customer support. This section further describes the purposes and legal basis for our processing of your personal data.


Information related to you and your account


Processing of your e-mail is mainly for the purpose of (i) providing you with our Service, or (ii) to answer questions, resolve problems or provide general support to our users. The legal basis for the processing is that the processing is necessary for the performance of a contract with you, or that the processing is based on a legitimate interest where our rights to process the data for such interest overrides your rights to your personal data.


Payment information


Payment information is mainly processed for the purpose of (i) providing you with our Service, (ii) to pay out refunds, and (iii) for accounting purposes. The legal basis for the processing of payment data for purpose (i)-(ii) is that the processing is necessary for the performance of a contract with you, or that the processing is based on a legitimate interest where our rights to process the data for such interest overrides your rights to your personal data. The legal basis for the processing of payment data for purpose (iii) is that the processing is necessary for compliance with a legal obligation to which we are subject.


Secondary purposes


Some of the personal data we collect might also be processed for the purpose of:


  • Verifying your identity when you log in to our site or are using our Service.
  • Completing your order.
  • Internal record keeping and improvement to our Site.
  • Sending promotional e-mails for services we think might interest you (please note that you can opt-out of this at any time).
  • To communicate with you about your VPN Service or respond to your communications.
  • Analyzing usage of our Site to better understand how our visitors use the Site and our Service.


The legal basis for the processing mentioned above is that the processing is necessary for the performance of a contract with you, or that the processing is based on a legitimate interest where our rights to process the data for such interest overrides your rights to your personal data.


Sharing of information


We will not disclose your personal data to any third party, except where (i) it has been agreed between PrivateVPN and you, (ii) it is necessary within the scope of our contract, (iii) it is necessary in order to fulfil a statutory obligation, comply with a decision of a public authority or court of law or (iv) in cases where we engage an external service provider or business partner who perform services on our behalf. We will never sell your personal data to third parties.


Any third party receiving your personal data from us must abide to this Privacy Policy and our security demands. Such third party is not allowed to use your personal data for any other purpose than providing the service in question.


In order to assist you if you have questions while using our Site or regarding the Service we offer the possibility of an online chat. For the use of such online chat, you will be requested to provide personal data such as name and e-mail. Our online chat is offered through LiveAgent. LiveAgent will have access to collect and process the personal data you provide in the online chat. We refer to their privacy policy and terms of use for further information about how they might be collecting and storing the information.


Transfers of personal data outside the EU/EEA are only carried out in accordance with applicable data protection laws and for the purposes specified above. Transfers may occur to countries outside the EU/EEA within the scope of a certain contract, but only to the extent necessary for the performance of our contract with you. In case of such third country transfer, we make sure to take all steps necessary to ensure your privacy. Transfer of personal data will only occur if the country to which the personal data will be transferred has been granted a European Commission adequacy decision or we have put in place appropriate safeguards in respect of the transfer, for example if we have entered into EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules. 


You may request more information about the safeguards that we have put in place in respect of transfers of personal data by contacting us via the contact information provided in this Privacy Policy.


Storage of information


The personal data is not saved longer than necessary given the purpose of the processing, unless a longer storage time is required or permitted by law. The data might be kept longer if required for tax, accounting, payment processing purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need - though we will generally not keep personal data for longer than two years following the last date of communication with you, unless the data is necessary in order to provide the Service.


Your rights as a data subject


You have the following rights in relation to our processing of your personal data:


Right to access (register transcript) – the right to obtain confirmation of and information about the processing of your personal data, and your rights as a data subject.


Right to rectification – the right to have your personal data corrected.


Right to erasure – known as “the right to be forgotten”, meaning the right to have your personal data erased. This right is not absolute and only applies in certain circumstances, e.g. when the processing is no longer necessary for its initial purpose or when we are processing the data based on your consent and you withdraw such consent.


Right to object – the right to object against our processing if the legal ground for the processing is based on our legitimate interests or if it is used for direct marketing.


Right to restrict data processing – the right to demand that the processing of personal data is restricted, e.g. if you oppose the correctness of the data. While the matter is investigated, PrivateVPN’s access to the data in question is restricted.


Right to data portability – the right to request that your personal data is transferred from one data controller to another. This right is restricted to the personal data that you have submitted to us.


Please note that if you request your personal data to be restricted or deleted, we may not continue to be able to fulfil our contractual obligations towards you. 


If you wish to exercise any of your rights, or wish to acquire more information regarding any of said rights, or the conditions for exercising them, we ask that you contact us via the contact information provided in this Privacy Policy.


Complaints


If you have any objections or complaints regarding our processing of your personal data, you are entitled to contact or file complaints with a supervisory authority, in Sweden currently the Swedish Data Protection Authority (Sw. Datainspektionen). You can also file a complaint with the supervisory authority in the country where you live or work.


Cookies


When you use our Site, you must agree to our use of cookies. For additional information about cookies, we refer to our Cookie Policy available at the Site.


Security


Our Site is protected by security measures that are consistent with the industry standard. These measures are to protects your personal data from theft, misuse, or loss. We continuously review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.


We restrict the access to personal data to our employees, contractors, and service providers who need the information in order to process it. Anyone with access to the information is informed and educated in how our security measures work and how we protect you as a user of our Service. We have chosen to work with well-known companies, and we make sure to collaborate with third parties that have a good reputation and will protect your personal data.


Marketing


We might use your e-mail address to send you promotional or marketing information about products or services related to our Service. You can choose to unsubscribe from these e-mails by contacting us at support@privatevpn.com. Please write “Unsubscribe” in the subject section.


Minors


Our Site and the Service we provide are not intended for anyone under the age of 18. When you subscribe to our Service, you warrant that you are at least 18 years of age. We do not use the Service to knowingly solicit data from children under the age of 18.


We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Privacy Policy by instructing their children never to provide personal information through the Sites or Service without their permission. If you have reason to believe that a child under the age of 13 (or applicable age in your country) has provided personal information to us through the Site or Service, please contact us at support@privatevpn.com.


Data controller


Privat Kommunikation Sverige AB, Reg. No. 556895-1486, Bygdevägen 5 lgh 1301, SE-191 48 Sollentuna, Sweden is the controller of the personal data processing as described above. This means that we are responsible for ensuring that the personal data is processed correctly and in accordance with applicable data protection laws.


Contact details


If you have any questions regarding our processing of your personal data, please e-mail us at: support@privatevpn.com. We try to answer all e-mail inquiries within 24 hours.


Changes to the Privacy Policy


We reserve the right to amend the Privacy Policy to comply with changes made to the relevant data protection legislation or our processing of personal data. If we do so we will change the effective date in the beginning of this Privacy Policy. If you continue to visit our Site or use our Service after the amendments, then you agree to the revised Privacy Policy. The current version of the Privacy Policy is available on the Site.