Last Updated: 27th of January 2021
We may provide additional privacy notices to you at the time we collect your data. This type of an “in-time” notice will govern how we may process the information you provide at that time.
1. Information we gather
As you most probably realise, we can’t offer a great service without gathering some information about you, such as your IP address, username, which we require to offer basic VPN functionality. We required your IP-Address to initialise the connection and safe guard our servers from cyber attacks and malicious behaviour, we do not use your IP-Address for any other purposes. In addition to your IP-Address we obviously need to store your user details somewhere as otherwise it’s impossible for us to verify you as a paying customer of CyberCat VPN. We also gather information when you download our applications from advertising campaigns on various platforms
Information we gather, whether directly or automatically may be regarded as personal information under certain jurisdictions under the European GDPR (General Data Protection Regulation). When we refer to personal information in this policy we refer to personal data as defined by the laws in relevant legal jurisdiction.
Types of personal information that we collect:
1.Identifiers – Unique personal identifier (UUID, Advertising ID, IDFA), IP address, or other similar identifiers.
2. Login information – We store username and passwords information, which we need to authenticate users in our system.
3. Network activity or other similar internet activity – Information regarding a consumers or users interaction with our website or application, however, this does not include browser history.
Sources of Information and Purposes of Use
Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others.
2. Information collected from you
The following are examples of the types of information you choose to give us when using our services:
-Your IP Address in CyberCat VPN
-If you communicate with our support team, we collect the information you give us during the interaction such as e-mail/message history so to serve you best.
3. Information gathered automatically
Automated Information includes information such as:
-Your Operating system used (e.g iOS13.2)
-Your IP address when accessing our network
-Device Information (e.g. iPhone X)
Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
-Cookies on / off
-Dates and times of access
This Automatically Gathered Information is generally used for the following purposes:
– To ensure the technical provision of our service so that we are able to provide you with a functioning user-friendly experience.
– To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
– To facilitate your access to our website or mobile application
– To customize our Services for you.
– To help us better understand our current and potential customers so that we may market our products and services accordingly.
Information collected from integrated services.
We may obtain information, from third parties and sources that we integrate into our services either for the provision of our Services or to facilitate your access to our services such as described below:
We may receive information about you from our partners, who may pass along details on a campaign’s success).
When you purchase any CyberCat VPN subscription, neither Google nor Apple provide us with any personal information of the subscription purchaser (for example name, email or payment information). The only information provided to us is an anonymized Subscription ID or Order ID.
4. How we may use your personal information
When you use our Services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Services. See below for more details.
Within the CyberCat VPN app, we collect information from and about the device(s) you use to access our Services, including:-
From when you open the App
Our servers automatically record information about how a person uses the app, including app install source, IP addresses, app versions, receipt, app name, operating systems, device models, device languages, subscription status, transient user-tokens, password-tokens and device country settings.
We also use a users IP addresses to generate aggregate, non-identifying information about how CyberCat VPN is used and also to develop features to protect us against cyber attacks. The information for protecting our servers is not stored permanently.
We do not connect this information to your internet browsing activities when using our VPN, nor do we log this information when you use VPN to browse the internet.
From moment you turn on CyberCat VPN software
Your browsing activity becomes encrypted, meaning it becomes invisible to ISPs and third party snoopers.
We have a strict no-logs policy when it comes to seeing user activity online. We only keep the IP addresses for 30 days and the IP addresses are not related to your internet traffic routed through our CyberCat VPN servers.
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:
Performing Our Services
Maintaining or servicing accounts, providing customer service, operating our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments.
Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions.
Understanding and evaluating how our services and features perform with our users.
Uncovering insights about usage in order to improve the services and provide customers with enhanced features as well as inform our development of new features and products.
Development of customized or personalized experiences of our Services, such as remembering your information so you do not have to re-enter it each time you use one of our Services.
Auditing Interactions with Consumers
measuring usage of our websites and mobile applications.
measuring our marketing activity (e.g., measuring how a user was acquired).
To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.
Identification and repair of impairments to intended, existing functionality of our Services.
Understanding our customer in order to more effectively market our Services.
Quality and Safety Maintenance and Verification
Activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services.
Verification or maintenance of the quality or safety of Services.
Tracking and responding to quality and safety matters.
Protecting our rights and property.
Complying with legal or regulatory requirements, judicial process, industry standards and our company policies, please see our Terms of Service.
Other purposes that may be described at the time you choose to provide personal information to us.
We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
5. How We May Share Information about You with Others
For clarity, VPN IP or usage data (i.e. network activity) is never shared.
6. Third Party Service Providers
We may share information about you with the following categories of third-party providers for a variety of business purposes:
Customer Communications and Insights Platforms. We may share email, app usage and interactions with our third party customer communications platform provider for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics.
Internal Business Insights Platforms. Our third party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, device id, IP address and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively.
Measurement and Attribution. These service providers offer tools that allow us to measure and attribute the source of new subscription sign ups and that allow us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety.
Other technology providers necessary to provide our services (including cloud storage and web hosting providers). An example is our hosting partners where we store IP Address in CyberCat VPN – however we delete it after 30 days.
7. Social Media
If you choose to communicate with us or another user through social features available on our websites or mobile applications or through our social media pages, or other similar communication or messaging features or services, such information may be made publicly available. For security purposes, please do not include any password, social security number, payment card or other sensitive information via these communication methods. We have the right, but not the obligation to monitor messages and communications between and among users for security and training purposes. We may, but are not obligated to, remove any content we deem inappropriate.
8. Information for Individuals in the European Economic Area (EEA)
Your Choices and Rights.
As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:
Access: you may request access to your personal information and receive copies of it;
Correction: you may have inaccurate/incomplete personal information corrected and updated;
Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
Deletion: in certain circumstances, you can request a right “to be forgotten” (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.
If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may contact us here. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our VPN service or some of the features and functionality of our Services. In addition, you may contact us here to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors). Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our Service to you anymore.
For your protection, we may require proof of identity and verification before we can answer the above requests.
9. Legal basis for processing data
In this section, we identify the legal grounds on which we rely to process personal information.
In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and Services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition).
In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.
It may be also necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.
Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting.
We may also process personal information as specifically permitted by applicable legal requirements.
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
10. Data Deletion Rights
Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.
11. Sale of Personal Information
We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your personal information as defined by the CCPA.
12. Access, Edit and Delete Your Information.
If you are not a resident of the EEA or California, depending on your location, you may be able make requests to access, correct and/or delete certain personal information that you provide to Smooth. For your protection, we may require proof and verification of identity and jurisdiction of residency before we can answer the above requests. If you wish to make such a request, you may contact us at the applicable mobile application support email. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide to you our Services or some of the features and functionality of our services. Once we have verified that you own the account, we will honor such requests at our discretion and in accordance with applicable law.
13. Device permissions
Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the Service’s Settings screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
15. Email communications
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by the applicable mobile application support email. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the Services.
16. Data Retention
Except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using our Services or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using our Services so we encourage you to contact us if you are no longer using the Services. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.
17. How We Protect Personal Information
We use various efforts intended to safeguard the security and integrity of personal information collected through our Services. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.
If you correspond with us by e-mail or using Web forms available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.
If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can change that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
18. Links to Websites and Third-Party Content
For your convenience and information, we may provide links on our website to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.
20. How to Contact Us
For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached here.
Our support team can be contacted support @ cybercatvpn.com
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