Paygvpn

Privacy Policy

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Privacy NoticeWe at Critical Dynamics value individuality, we value each and every one of you who use our product to browse the Internet freely or who just interact with our website. We appreciate the value of your trust and have chosen to do so by committing to respect your fundamental rights, including the right to privacy and data protection. As such, this Privacy Notice is designed to explain when and why we collect personal data about you, how we use it, the conditions under which we can disclose it to others, how we keep it safe and secure, and your rights and choices in relation to your information. It is important that you read this Privacy Notice together with our Cookies Notice and any other notice we will provide on certain, specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.ScopeThis Privacy Notice applies to your access to and use of the website located at www.paygvpn.com and any other website, microsite, mobile device application, or Internet property owned, or operated by Critical Dynamics, and related services. It also describes the personal data we collect from these sites and services and how it is used, including information we collect when you register for use of the websites.Who are we?Critical Dynamics is a boutique cybersecurity company specialising in the procurement of secure software solutions. In this notice,‘Critical Dynamics’, ‘we’, ‘us’ or ‘our’ means: Critical Dynamics OU Sepapaja 6 Tallinn, 15551 Estonia Any questions regarding this notice and our privacy practices should be sent to info@criticaldyn.com For what purposes is your data processed?Your data is processed for the following purposes: Account registration – To register your user account. When registering your account, we process basic data such as your device ID and device type information to generate your unique account ID. We also ask you to create a password to keep your account secure. Service delivery – To enable you to use our Virtual Private Network (VPN) solution. Operating a VPN solution entails that we process your IP address at a minimum in order to effectively reroute traffic through the servers that can deliver optimal performance of the service. By virtue of having this IP address, we will implicitly get insight as to the country and city from where you are accessing the service. Analytics – To improve our service and generate insight for future products/services. The analytics platforms we leverage to monitor website traffic require basic device information to operate effectively such as IP address, device ID and type. For more information, please, refer to our Cookie Notice. Payment processing – To make available the facility for settling payment transactions. You can subscribe to use our VPN solution while taking advantage of the two payment options we provide, namely, the in-app purchasing gateways provided by both Google and Apple, and the payment platform operated by Stripe. The information required to process transactions through these payment facilities is outlined within those vendors’ policies which you can access via the following links: Google – https://policies.google.com/privacy?hl=en Apple – https://www.apple.com/legal/privacy/data/ Stripe – https://stripe.com/privacy Customer support – To manage our relationship with users on an ongoing basis. As a responsible VPN provider, we believe it is our duty to support our customers in making the most out of our solution. To enlist our assistance, you can just e-mail us at the address above – please, make sure to include your account ID in the subject line – so we can review your message and respond accordingly. In those cases where we look to introduce optional extras to our VPN solution or, perhaps, expand our offering with a new product, we would like to e-mail you about that and give you the chance to benefit from any such improvements. Regulatory compliance – To comply with our regulatory obligations. Just as any other legal entity, we are obliged to process financial information in order to prepare our tax statements but also to cooperate with authorities should we be presented any official requests for audits. Thus, especially within the scope of our tax obligations, we have to process payment information to remit the requisite amount of tax as legally required. On what basis do we process your data?Performance of a contract – When necessary to perform a contract to which you are a party or to take steps at your request before entering into a contract. For example, to register your user account or to process any payments associated with the use of our VPN solution. Legal obligation – When necessary to perform a legal obligation. For example, to retain payment information for the purpose of complying with potential tax audits. Consent – When you have consented to the specific processing activity. For example, to monitor the traffic to our website by virtue of placing a cookie on your device (see our Cookie Notice for additional information).For how long do we retain your data?Depending on the purposes for which we process your data, it will be retained as necessary for the following: Account registration – To maintain your user account for as long as you want it to remain active and for a period of three years thereafter for the exercise or defence of legal claims. Service delivery – To continue providing the service you subscribed to for as long as your account remains active and for a period of three years thereafter for the exercise or defence of legal claims. Analytics – To derive insight from your interactions with our website or until you withdraw your consent. Payment processing – To make available the facilities for settling payment transactions so long as your account remains active and for a period of three years thereafter for the exercise or defence of legal claims. Customer support – To manage our relationship with you for so long as your account remains active and for a period of three years thereafter for the exercise or defence of legal claims. Regulatory compliance – To prepare and submit any tax statements in compliance with our annual tax reporting obligations, and for a period of 7 years thereafter for the purpose of complying with general taxation requirements. Who can receive your data?In fulfilling the purposes outlined above, we expect to share your data with the following organizations: Amazon Web Services – Cloud storage. Google/Firebase – Office software, e-mail, analytics and in-app payment processing. Apple – In-app payment processing. Stripe – Payment processing. Accounting company – Bookkeeping and accounting services. Authorities – Regulatory compliance. What are your rights?When it comes to your data, you have been afforded the rights listed below and you can exercise them by contacting us at info@criticaldyn.com: Right of access – You can request a copy of the personal data we hold about you. For example, if you created an account on our website, you can request that we send you a copy of the information we hold about you. However, if we are unable to associate the information with you, it can be excluded from our response. Right to rectification – If we have entered your personal data incorrectly, you can request that we fix it. For example, if your payment information has changed because you have recently opened an account with another financial institution, you can ask us to amend our records to reflect that. Right to erasure (‘right to be forgotten’) – You can request that we delete all your personal data. For example, you can request that we delete your account and any communication you have exchanged with us when contacting us for customer support purposes. However, be mindful that there are circumstances when such requests can be denied, including when we need to continue processing your data to comply with legal obligations imposed on us or for the exercise or defence of legal claims. Right to restriction of processing – In the case we enter into an argument regarding the processing of your data, you can request that we stop processing it until the argument is resolved. For example, you can request we stop processing your data because its accuracy is contested. However, the restriction will last until this particular issue is resolved as opposed to indefinitely. Right to data portability – You can receive all of your own data in commonly-readable format. For example, you can request we send your data to another provider. However, such requests can only be made with respect to data processed on the basis of your consent or contractual necessity. Right to lodge a complaint – You have the right to lodge a complaint with the Supervisory Authority in the country where you reside, work or where the alleged infringement took place. For example, if you reside in the United States, you can lodge your complaint with the Data Protection Inspectorate in Estonia. Changes to this Privacy Notice.We try to keep this Privacy Notice up to date at all times but, should we introduce any changes, we will endeavour to list them in this section for ease of reference. Last updated: May 26th, 2021