Privacy Policy
Dec 10 2020
X-VPN is a global company and committed to protecting your privacy.
X-VPN is offered by Free Connected Limited.
This Privacy Policy describes how Free Connected
Limited("X-VPN", "we" or "us") controls ("collect", "use", "disclose" or "protect") our users'
("your") personal data and how can our users control their data.
This Policy applies to all services
(collectively as the "Service") offered by X-VPN (Software versions like Windows, Mac, Android, iOS,
Linux, Chrome Extension and others) and X-VPN official websites.
Your consent is the legal basis for data collecting and processing.
By
visiting or using the Service, you consent to the terms set forth in this Privacy Policy.
As an internet privacy &.
security service provider, we make sure your
privacy is our primary concern, and we will be 100% transparent with our users.
We believe the
relationship between the users and us is built on trust, and trust is built on the truth.
To offer
better clarity for you, let's start with three points:
We do not log how you utilize VPN connection, which means we do not see the applications, service or websites you use personally while connected
to our Service nor do we store them.
We do not store your original IP address or the
server IP address that you connect to which means we cannot share it to anyone no matter
what happened.
We will not sell, use, or disclose any personal
data to third parties not mentioned in this Privacy for any purpose.
Our guiding principle toward data collection is to collect only the
minimal data required to operate a world-class VPN service at scale.
We designed our systems to not
have sensitive data about our customers.
even when compelled, we cannot provide data that we do not
possess.
Categories of Personal
Data, How &.
Why（Include the data over the past 12 months）
ACCOUNT DATA
Such as registration date, email address (only if you choose to sign up
with an email), subscription status (only if you make the purchase).
<br>This data is automatically
collected during actions including registration, purchase.
It is strictly used for the user-support
purpose.
VPN USAGE DATA
Such as the connection timestamp, choice of the protocol, network type
and error report;<br>This data is automatically collected during VPN connection and is used for
troubleshooting &.
VPN service optimization only.
STATUS DATA
Such as your device information, app version, data usage and
geolocation(only city-level) <br>This data is automatically collected when you open and use X-VPN
and it helps us to better understand our users and product planning, to further improve the user
experience and user satisfaction.
PAYMENT DATA
Such as payment method, transaction ID (or reference ID) and timestamp.
<br>This data is automatically collected by us when you make a purchase and is used for user support
and troubleshooting only.
Virtually, more information including geolocation, cardholder last name
and last four digits of the Credit card may be collected independently by a third-party payment
platform which is separated from our internal system.
OTHER INFORMATION
Defense data: when you try to sign in or sign up on our site, we may
collect your original IP address which is deleted automatically in 5 minutes to prevent Brute force.
We cannot see the IP address or download it during that period.
<br>Analysis data: such as sites
visited via our servers from all users, it is anonymous aggregated data mixed from our tens of
millions users which is non-identifying.
we do not attribute any website visit or app usage to any
specific user.
Feedback records: only if you use X-VPN Customer service chat system or you send e-mails to our official support e-mail address to feedback the problems you encounter, then the we will record your feedback to provide solutions.
<br>
Application control: For those who use the application control function, this function will require X-VPN to access your inventory of installed apps.
Please noted that we do not log that information.
<br>
X-VPN uses your personal information only for the purposes listed in
this Privacy Policy, and we do not sell your personal information to third
parties.
Data Retention We retain essential data such as <b>account data, status data</b>, payment data and feedback records to maintain the Service, unless you request a deletion.
<br>
Besides, <b>VPN usage data</b> will be kept for <b>LESS THAN 48 HOURS</b> for the purpose of user-support and then automatically erased from our system permanently after that period.
We store your Personal Data only as long as it is necessary for the
purposes for which it is collected, to provide our Services, resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply
with applicable laws.
We erase or destroy the records containing Personal Data when they are no
longer required.
this will be done in ways that will ensure your continued privacy.
Data Control
Free Connected Limited is the Data Controller of the information you
provide us.
Data Transfer
We store our users' information on servers within the EU while we are a
Hong Kong company.
Though most of the calculations are automatically done in the cloud, we may need
to access users' data internationally when necessary (e.g., when user support is required).
Please
be aware that Hong Kong may not have the same level of data protection as the European Economic
Area, however our collection, storage and use of your personal data will continue to be governed by
this Privacy Policy.
Data Security
We are committed to protecting our users' personal data as we have
various technical and organizational measures in places to ensure, e.g., our system will erase the
user's original IP addresses automatically if any, and only our authorized employees have the access
to the data.
X-VPN uses exceptionally strong safeguards to protect the privacy of
all our records, including your Personal Data.
We implement physical, business and technical
security measures.
These strong safeguards are designed to prevent unauthorized access, disclosure,
loss, theft, copying, use or modification to your Personal Data.
Cookies
We use the following cookies to help us provide better services on our
websites: Cookies: These cookies store your preference,
logins on our site to provide you a fluid experience and will be erased when you close your browser.
Google Analytics: The tool uses a series of
cookies to collect information and generate a report on website usage statistics, but does not
disclose any personally identifiable information.
You may change your browser or devices' settings to disable or refuse
certain cookies on our site.
Please note that disables certain cookies may result in inaccessibility
of our services on the websites.
Third-Party
The Third-Party Site may contain links to external websites that do not
fall under X-VPN's domain.
X-VPN is not responsible for the privacy practices or content of such
external websites.
Some third parties may be able to collect certain information from you
independently from us including third-party payment platforms, analytics-tool providers or
advertisers.
You can find the information of such third parties listed here, as updated from time to
time:
Paymentwall, PayPal, GiftCards, ADVcash,
CoinPayments, Adjust, Google Analytics, GCM, AdMob, Applovin, Mopub, Vungle, Fabric, ironSource,
InMobi, StartApp, etc.
Consent and Age Restrictions
By using the Site, Content, Apps, Software, or Services, you agree to
have your information handled as described in our Terms of Service and Privacy Policy.
<br>We do not
log information from children under 18 intentionally as the Service is not direct to anyone under
the age of 18.
DO NOT USE the Service if you are not of legal age.
Rights of Access, Rectification, Deletion, and Restriction
You have the right to inquire as to whether X-VPN is Processing
Personal Data about you, request access to Personal Data including the categories of personal
information we have collected about, and the categories of any of your personal information that we
have disclosed for business purpose.
You have the right to ask that we correct, amend or delete your
Personal Data.
In each case, X-VPN provides this information: We provide the receipt
of a Verifiable Consumer Request without charge, ,and you can request us up to 2 occasions every 12
months.
We will send you a portable, readily-usable format (e.g.
XML, or CSV,etc) within 45 days.
If
reasonably necessary, we may extend this period by an additional 45 days after we notify you.
How to Exercise the Right to Access, Rectification, Deletion, and
Restriction
Send an email to support@xvpn.io
You can use the contact ways to request access to, receive, restrict,
or request deletion or rectification of Personal Data held about you by X-VPN.
To protect your privacy, X-VPN requires you to login to your account
with a username and password before granting you access to or allowing you to make any changes to
your Personal Data.
X-VPN makes good faith efforts to provide you with the ability to delete your
Personal Data, however there may be circumstances in which X-VPN is unable to delete all your
Personal Data.
For example, we are unable to delete it where we are legally required to keep it,
including where we need it to continue to offer you the service.
If X-VPN determines that your Personal Data cannot be deleted, we will
explain why and provide a contact for further inquiries.
If you have any questions about our privacy practices, this Privacy
Policy, please contact X-VPN by email at support@xvpn.io.
We
will address your concerns and attempt to resolve any privacy issues in a timely manner.
Users in the European Union:
This section applies to individuals in the European Union and to
individuals in other countries whose data privacy laws are similar to GDPR.
Your Rights
As a Data Subject you have rights under the GDPR.
These rights can be
seen below.
X-VPN will always fully respect your rights regarding the processing of your personal
data, and has provided below the details of the person to contact if you have any concerns or
questions regarding how we process your data, or if you wish to exercise any rights you have under
the GDPR.
(Chapter 3 of the GDPR) each Data Subject has eight rights.
These are: <ol>
<li>The right to be informed.
This means anyone processing your personal
data must make clear what they are processing, why, and who else the data may be passed to.</li>
<li>The right of access.
this is your right to see what data is held
about you by a Data Controller.</li>
<li>The right to rectification.
the right to have your data corrected or
amended if what is held is incorrect in some way.</li>
<li>The right to erasure.
under certain circumstances you can ask for
your personal data to be deleted.
This is also called 'the Right to be Forgotten'.
This would
apply if the personal data is no longer required for the purposes it was collected for, or your
consent for the processing of that data has been withdrawn, or the personal data has been
unlawfully processed.</li>
<li>The right to restrict processing.
this gives the Data Subject the
right to ask for a temporary halt to processing of personal data, such as in the case where a
dispute or legal case has to be concluded, or the data is being corrected.</li>
<li>The right to data portability.
a Data Subject has the right to ask
for any data supplied directly to the Data Controller by him or her, to be provided in a
structured, commonly used, and machine-readable format.</li>
<li>The right to object.
the Data Subject has the right to object to
further processing of their data which is inconsistent with the primary purpose for which it was
collected, including profiling, automation, and direct marketing.</li>
<li>Rights in relation to automated decision making and profiling.
Data
Subjects have the right not to be subject to a decision based solely on automated processing.
</li>
</ol>
Legal Basis
X-VPN is committed to user privacy globally, and our existing practices
reflect that through minimal collection of data and ensuring users have control over their personal
information.
The General Data Protection Regulation (GDPR) of the European Union (EU) requires us to
outline those practices in a specific manner for users in the EU.
In line with the GDPR, we collect and process the data outlined in this
Privacy Policy on one of the following bases, depending on the circumstances:
1.
For the purposes of fulfilling our contractual obligations to users,
including:
Providing users with the Services and Apps they have
requested.
Managing user subscriptions and processing payments.
Providing customer support.
2.
For a legitimate interest associated with the operation of our
business, including:
Enhancing the quality, reliability, and effectiveness of our
Site, Services, and Apps.
Communicating with customers to provide information and seek
feedback related to our Services and Apps.
You can exercise your rights under the GDPR to access, transfer,
correct, delete, or object to the processing of your personal information by contacting us at: support@xvpn.io (Please note that we may need one month or
longer to respond)
Users in California
X-VPN does not share information that identifies you personally with
non-affiliated third parties for our own marketing use without your permission.
California Consumer Privacy Act
Non-Discrimination
We will not discriminate against you for exercising your CCPA rights.
Unless permitted by the CCPA, we will not:
<ol>
<li>Deny you goods or services.</li>
<li>Charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or imposing penalties.</li>
<li>Provide you a different level or quality of goods or services.</li>
<li>Suggest that you may receive a different price or rate for goods or
services or a different level or quality of goods or services.</li>
</ol>
Users in Nevada
X-VPN does not sell information that identifies you personally with
non-affiliated third parties.
X-VPN will not sell or trade Personal Data for commercial purposes.
Reseller Privacy Policy
If you participate in our Reseller Program, please refer to it's privacy policy here.
Changes to the Privacy Policy
We may need to change our Privacy Policy from time-to-time and all
updates will be posted online, consistent with applicable privacy laws and principles.
Your
continued use of our Site or Services after the effective date of such changes constitutes your
acceptance of our Privacy Policy.
We will post an effective date at the top of the page for your
convenience.
Here's the end of this Policy
Effective: Dec 10 2020
If you have any questions regarding our Privacy Policy and how we
handle your information, Please feel free to contact X-VPN at the following email address: support@xvpn.io