Privacy policy
At OrbVPN, we stand behind our commitment to user privacy and
security. When you use our OrbVPN Apps and Services, you’ll share some
information with us, which we use to provide and improve those Apps
and Services, 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 therefore, this privacy policy ("Policy")
describes how the personally identifiable information ("Personal
Information") you may provide in the "OrbVPN"
Application ("Apps" or "Application") and any of
its related products and services (collectively, "Services")
is collected, protected and used. It also describes the choices
available to you regarding our use of your Personal Information and
how you can access and update this information. OrbVPN will never
collect, store, log, or share any browsing activity, your true IP
address, including no logging of browsing history, traffic
destination, data content, or DNS queries, and we always delete your
true IP address after your VPN session is closed. Since we only
collect the minimal usage statistics needed to maintain the quality of
our service, and do not store users’ personal information, we cannot,
willingly or unwillingly, share user information with third-parties or
government authorities - because this data does not exist. We never
associate your email, true IP address, username, or unique mobile ID
with your browsing information or online activities when you are using
OrbVPN. Creating an account is always optional – we never require you
to register or otherwise provide us any personal information to
download or use our products. We only use your information to provide
you with our Apps and Services that we are constantly working to
improve. This Policy is a legally binding agreement between you
("User", "you" or "your") and OrbVPN
("OrbVPN", "we", "us" or
"our"). By accessing and using the product and Services, you
acknowledge that you have read, understood, and agree to be bound by
the terms of this Agreement. This Policy does not apply to the
practices of companies that we do not own or control, or to
individuals that we do not employ or manage.
Automatic collection of information
When you use the Application, our servers automatically record
information that your device sends. This data may include information
such as your device's IP address and location, device name and
version, operating system type and version, language preferences,
information you search for in the Application, access times and dates,
information about your hardware and software, from device sensors,
about your wireless and mobile network connections, , Information
Collected by Cookies and Other Technologies and log information.
Information collected automatically is used only to identify potential
cases of abuse and establish statistical information regarding the
usage of the Apps and Services. This statistical information is not
otherwise aggregated in such a way that would identify any particular
user of the system.
Collection of personal information
OrbVPN online collects some personal information from registered
users. During the registration’s users have to input a username,
password, and a valid email address. OrbVPN uses your email address
for the following reasons:
- To send emails related to payment transactions.
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To provide links to our website, including password reset emails.
- To send you updates and announcements.
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To communicate with you about your VPN services or respond to your
communications.
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To send marketing information, such as OrbVPN offers, surveys,
invitations, and content about other matters in connection with
OrbVPN (“Marketing emails”). You can unsubscribe from the
marketing and promotional materials at any time using the
corresponding links in the emails.
You can access and use our Apps and Services without telling us who
you are or revealing any information by which someone could identify
you as a specific, identifiable individual. If, however, you wish to
use some of the features in the Application, you may be asked to
provide certain Personal Information (for example, your name and
e-mail address). We may also receive a confirmation when you open an
email from us. When purchasing Services, you will be required to
provide additional information that may include a credit card number
or other banking or payment information ("Billing
Information"). OrbVPN app online has no access to your database
password or any data stored in your local database on your devices. If
you are using OrbVPN online data records or tasks synchronization and
backup service, the OrbVPN online will have access to the encrypted
binary file on our servers which contains your database. We need this
access to provide you a secure backup and restore of your local
personal database in case you have lost or damaged your device. OrbVPN
online will have no access to the data stored in this database. We
receive and store any information you knowingly provide to us when you
fill any online forms in the Application. When required, this
information may include the following:
- Personal details such as name, country of residence, etc.
- Contact information such as email address, address, etc.
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Account details such as username, unique user ID, password, etc.
- Geolocation data such as latitude and longitude.
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Information about other individuals such as your family members,
friends, etc.
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Any other materials you willingly submit to us such as articles,
images, feedback, etc.
Some of the information we collect is directly from you via the Apps
and Services. However, we may also collect Personal Information
about you from other sources such as public databases and our joint
marketing partners. You can choose not to provide us with your
Personal Information, but then you may not be able to take advantage
of some of the features in the Application. Users who are uncertain
about what information is mandatory are welcome to contact us.
Other than as disclosed in this Privacy Policy, OrbVPN Application
online at no time will disclose identifiable personal data, if any, to
any third parties without your express, written approval.
Use and processing of collected information
In order to make our Apps and Services available to you, or to meet a
legal obligation, we need to collect and use certain Personal
Information. If you do not provide the information that we request, we
may not be able to provide you with the requested products or
services. Any of the information we collect from you may be used for
the following purposes:
- Request user feedback
- Improve user experience
- Enforce terms and conditions and policies
- Protect from abuse and malicious users
- Respond to legal requests and prevent harm
- Run and operate the Apps and Services
Processing your Personal Information depends on how you interact with
the Apps and Services, where you are located in the world and if one
of the following applies: (i) you have given your consent for one or
more specific purposes; this, however, does not apply, whenever the
processing of Personal Information is subject to California Consumer
Privacy Act or GDPR ; (ii) provision of information is necessary for
the performance of an agreement with you and/or for any
pre-contractual obligations thereof; (iii) processing is necessary for
compliance with a legal obligation to which you are subject; (iv)
processing is related to a task that is carried out in the public
interest or in the exercise of official authority vested in us; (v)
processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party. Note that under some legislations
we may be allowed to process information until you object to such
processing (by opting out), without having to rely on consent or any
other of the following legal bases below. In any case, we will be
happy to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal
Information is a statutory or contractual requirement, or a
requirement necessary to enter into a contract. We may also obtain
information from our affiliates and third parties. Here are a few
examples: Advertisers may let us know you installed a new app or game
so we can determine whether we showed you an ad for it. If you
interact with one of our advertisers, they may share information with
us to help target or measure the performance of ads. You can learn
more about these types of ads in our Support Center.
Managing information
You are able to delete certain Personal Information we have about you.
The Personal Information you can delete may change as the Apps and
Services change. When you delete Personal Information, however, we may
maintain a copy of the unrevised Personal Information in our records
for the duration necessary to comply with our obligations to our
affiliates and partners, and for the purposes described below. If you
would like to delete your Personal Information or permanently delete
your account, you can do so by contacting us. What do we do with the
information we collect? For the detailed answer, go here. The short
answer is: Provide you with an amazing set of products and services
that we relentlessly improve. Here are the ways we do that:
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Develop, operate, improve, deliver, maintain, and protect our
products and services.
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Send you communications, including by email. For example, we may
use email to respond to support inquiries or to share information
about our products, services, and promotional offers that we think
may interest you.
- Monitor and analyze trends and usage.
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Personalize our services by, among other things, suggesting
friends or profile information, or customizing the content we show
you, including ads.
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Contextualize your experience by, among other things, tagging your
Memories content using your precise location information (if, of
course, you’ve given us permission to collect that information)
and applying other labels based on the content.
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Provide and improve ad targeting and measurement, including
through the use of your precise location information (again, if
you’ve given us permission to collect that information), both on
and off our services.
- Enhance the safety and security of our Apps and Services.
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Verify your identity and prevent fraud or other unauthorized or
illegal activity.
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Use information we’ve collected from cookies and other technology
to enhance our services and your experience with them.
- Enforce our Terms of Use and other usage policies.
Control over your information
We want you to be in control of your information, so we provide you
with the following tools. Because your privacy is important to us, we
may ask you to verify your identity or provide additional information
before we let you access or update your personal information. We may
also reject your request to access or update your personal information
for a number of reasons, including, for example, that the request
risks the privacy of other users or is unlawful. Revoking permissions.
If you let us use your information, you can always change your mind
and simply revoke your permission by changing the settings on your
device if your device offers those options. Of course, if you do that,
certain services may lose full functionality. Advertising Preferences.
We try to show you ads that we think will be relevant to your
interests. If you would like to modify the information, we and our
advertising partners use to select these ads, you can do so in the
app. Communicating with other users. It’s important to us that you
stay in control over whom you communicate with.
Disclosure of Information with Third Parties
Depending on the requested Services or as necessary to complete any
transaction or provide any service you have requested, we may share
your information with your consent with our trusted third parties that
work with us, any other affiliates and subsidiaries we rely upon to
assist in the operation of the Application and Services available to
you. We do not share Personal Information with unaffiliated third
parties. For example, if another user allows us to collect information
from their device phonebook—and you’re one of that user’s contacts—we
may combine the information we collect from that user’s phonebook with
other information we have collected about you. We may also obtain
information from our affiliates and third parties. Here are a few
examples: Advertisers may let us know you installed a new app or game
so we can determine whether we showed you an ad for it. If you
interact with one of our advertisers, they may share information with
us to help target or measure the performance of ads. You can learn
more about these types of ads in our Support Center. We will disclose
any Personal Information we collect, use or receive if required or
permitted by law, such as to comply with a subpoena, or similar legal
process, and when we believe in good faith that disclosure is
necessary to protect our rights, protect your safety or the safety of
others, investigate fraud, or respond to a government request. You
acknowledge and agree that we are not responsible for how those third
parties collect or use your information. As always, we encourage you
to review the privacy policies of every third-party service that you
visit or use, including those third parties you interact with through
our services. To learn more about third- party services in OrbVPN
Online, visit our Support Site.
Retention of information
We will retain and use your Personal Information for the period
necessary to comply with our legal obligations, resolve disputes, and
enforce our agreements unless a longer retention period is required or
permitted by law. We may use any aggregated data derived from or
incorporating your Personal Information after you update or delete it,
but not in a manner that would identify you personally. Once the
retention period expires, Personal Information shall be deleted.
Therefore, the right to access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced
after the expiration of the retention period.
Transfer of information
We may collect your personal information from, transfer it to, and
store and process it in the United States and other countries outside
of where you live. Whenever we share information of EU users outside
the EU we make sure an adequate transfer mechanism is in place
The rights of users
You may exercise certain rights regarding your information processed
by us. In particular, you have the right to do the following: (i) you
have the right to withdraw consent where you have previously given
your consent to the processing of your information; (ii) you have the
right to object to the processing of your information if the
processing is carried out on a legal basis other than consent; (iii)
you have the right to learn if information is being processed by us,
obtain disclosure regarding certain aspects of the processing and
obtain a copy of the information undergoing processing; (iv) you have
the right to verify the accuracy of your information and ask for it to
be updated or corrected; (v) you have the right, under certain
circumstances, to restrict the processing of your information, in
which case, we will not process your information for any purpose other
than storing it; (vi) you have the right, under certain circumstances,
to obtain the erasure of your Personal Information from us; (vii) you
have the right to receive your information in a structured, commonly
used and machine readable format and, if technically feasible, to have
it transmitted to another controller without any hindrance. This
provision is applicable provided that your information is processed by
automated means and that the processing is based on your consent, on a
contract which you are part of or on pre-contractual obligations
thereof.
The right to object to processing
You have the right to object to our use of your information. With many
types of data, we’ve provided you with the ability to simply delete it
if you don’t want us processing it anymore. For other types of data,
we’ve given you the ability to stop the use of your data by disabling
the feature altogether. You can do these things in the app. If there
are other types of information you don’t agree with us processing, you
can contact us.
Data protection rights under GDPR
If you are a resident of the European Economic Area (EEA), you have
certain data protection rights and we aim to take reasonable steps to
allow you to correct, amend, delete, or limit the use of your Personal
Information. If you wish to be informed what Personal Information, we
hold about you and if you want it to be removed from our systems,
please contact us. In certain circumstances, you have the following
data protection rights:
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You have the right to request access to your Personal Information
that we store and have the ability to access your Personal
Information.
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You have the right to request that we correct any Personal
Information you believe is inaccurate. You also have the right to
request us to complete the Personal Information you believe is
incomplete.
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You have the right to request the erase your Personal Information
under certain conditions of this Policy.
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You have the right to object to our processing of your Personal
Information.
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You have the right to seek restrictions on the processing of your
Personal Information. When you restrict the processing of your
Personal Information, we may store it but will not process it
further.
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You have the right to be provided with a copy of the information
we have on you in a structured, machine-readable and commonly used
format.
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You also have the right to withdraw your consent at any time where
we relied on your consent to process your Personal Information.
You have the right to complain to a Data Protection Authority about
our collection and use of your Personal Information. For more
information, please contact your local data protection authority in
the European Economic Area (EEA).
California privacy rights
In addition to the rights as explained in this Policy, California
residents who provide Personal Information (as defined in the statute)
to obtain products or services for personal, family, or household use
are entitled to request and obtain from us, once a calendar year,
information about the Personal Information we shared, if any, with
other businesses for marketing uses. If applicable, this information
would include the categories of Personal Information and the names and
addresses of those businesses with which we shared such personal
information for the immediately prior calendar year (e.g., requests
made in the current year will receive information about the prior
year). To obtain this information please contact us.
How to exercise these rights
Any requests to exercise your rights can be directed to us through the
contact details provided in this document. Please note that we may ask
you to verify your identity before responding to such requests. Your
request must provide sufficient information that allows us to verify
that you are the person you are claiming to be or that you are the
authorized representative of such person. You must include sufficient
details to allow us to properly understand the request and respond to
it. We cannot respond to your request or provide you with Personal
Information unless we first verify your identity or authority to make
such a request and confirm that the Personal Information relates to
you.
Privacy of children
Our Apps and Services are not intended for—and we don’t direct them
to—anyone under 13. And that’s why we do not knowingly collect
personal information from anyone under 13. In addition, we may limit
how we collect, use, and store some of the information of EU users
between 13 and 16. In some cases, this means we will be unable to
provide certain functionality to these users. If we need to rely on
consent as a legal basis for processing your information and your
country requires consent from a parent, we may require your parent’s
consent before we collect and use that information. In accordance with
the Federal Children's Online Privacy Protection Act of 1998
(COPPA), OrbVPN online does not intentionally collect nor solicit
personally identifiable information from children under the age of
thirteen (13) years of age.
Links to other resources
The Apps and Services contain links to other resources that are not
owned or controlled by us. Please be aware that we are not responsible
for the privacy practices of such other resources or third parties. We
encourage you to be aware when you leave the Apps and Services and to
read the privacy statements of each and every resource that may
collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled,
secure environment, protected from unauthorized access, use, or
disclosure. We maintain reasonable administrative, technical, and
physical safeguards in an effort to protect against unauthorized
access, use, modification, and disclosure of Personal Information in
its control and custody. However, no data transmission over the
Internet or wireless network can be guaranteed. Therefore, while we
strive to protect your Personal Information, you acknowledge that (i)
there are security and privacy limitations of the Internet which are
beyond our control; (ii) the security, integrity, and privacy of any
and all information and data exchanged between you and the Apps and
Services cannot be guaranteed; and (iii) any such information and data
may be viewed or tampered with in transit by a third party, despite
best efforts.
Data breach
In the event we become aware that the security of the Apps and
Services has been compromised or users Personal Information has been
disclosed to unrelated third parties as a result of external activity,
including, but not limited to, security attacks or fraud, we reserve
the right to take reasonably appropriate measures, including, but not
limited to, investigation and reporting, as well as notification to
and cooperation with law enforcement authorities. In the event of a
data breach, we will make reasonable efforts to notify affected
individuals if we believe that there is a reasonable risk of harm to
the user as a result of the breach or if notice is otherwise required
by law. When we do, we will send you an email, get in touch with you
over the phone.
Changes and amendments
We reserve the right to modify this Policy or its terms relating to
the Apps and Services from time to time in our discretion and will
notify you of any material changes to the way in which we treat
Personal Information. When we do, we will post a notification in the
Application. We may also provide notice to you in other ways in our
discretion, such as through contact information you have provided. Any
updated version of this Policy will be effective immediately upon the
posting of the revised Policy unless otherwise specified. Your
continued use of the Apps and Services after the effective date of the
revised Policy (or such other act specified at that time) will
constitute your consent to those changes. However, we will not,
without your consent, use your Personal Information in a manner
materially different than what was stated at the time your Personal
Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its
terms and conditions. By accessing and using the Apps and Services you
agree to be bound by this Policy. If you do not agree to abide by the
terms of this Policy, you are not authorized to access or use the Apps
and Services.
Contacting us
If you would like to contact us to understand more about this Policy
or wish to contact us concerning any matter relating to individual
rights and your Personal Information, you may send an email to
info@orbvpn.com