SnugVPN’s goal and unaltered Company policy is to be the world leader in data protection and user privacy. Our unequivocal Company policy is when you are using SnugVPN, your user traffic data, such as browsing history, traffic destination, search preferences, and data content are not monitored, logged, recorded, or stored. Our Company’s efforts are dedicated to protecting your user personal data, as defined herein, and ensure its safe storage.
We take our Company’s goals and policies very seriously.
1. Policy Coverage
This Policy applies to all Services that we offer via our entire suite of Apps and also applies to the Website as well as your use of SnugVPN (“Services”). This Policy does not apply to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party company before deciding whether to provide any information. By using our Website or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, please do not visit or use our Website or Services. Your continued use of our Website or Services will signify your acceptance of this Policy.
2. Data Collection
A. Personal Data.
When registering through our Website, you will be requested to provide your name, address, e-mail address, username, and payment information when you order or subscribe for our Services, as well as when you fill out any of the contact forms on the Website. This information is collected for proper administration of your account, customer support, and to provide our newsletter and occasional promotional offers. Additionally, as part of our fraud detection measures, we shall collect data relating (i) to Website usage information, such as IP address (captured and stored in an anonymized format), approximate location, and (ii) transaction information, items purchased, the price paid, billing method, partial credit card information, chargeback requests, cancelled orders. The above mentioned Personal Data is not, at any point, associated with any kind of activity done by the user inside the SnugVPN tunnel which is NOT recorded, logged or stored in any manner.
B. Non-Personal Data.
Additionally, we collect and store certain non-personal information (“Non-Personal Data”). When there is an exchange of information that occurs between your browser and our affiliates or our server, they automatically receive Non-Personal informational data relating to the browser you are using; mobile/desktop device; general properties and metadata; OS version; preferred language; the date and time of your visit; the referring website; and your preferences in our Websites during your visit. We collect such statistical information about usage as aggregate data from both the Website and Service in order to maintain a better customer experience as well as a high level of quality for the Service.
Non-Personal Data is not associated with or linked to your Personal Information or permit the identification of individual persons. Additionally, Non-Personal Data does not include any information about the activity performed by the user inside the SnugVPN tunnel such as browsing history, web content accessed, destinations of VPN traffic, DNS queries and IP addresses. We use this information for internal monitoring, analytics and improvement of our Services in the way described in this Policy. Additionally, at your sole discretion, you may approve VPN connection diagnostics which allows for app data to be sent by the user to the customer support team, similar to a “report a bug” feature. A connection log may also be sent together with a ticket that is raised with our customer support, so our team can debug any faults that may appear and result in a bad experience for the user.
3. Personal Data Collection
Our Website contains registration forms that will ask users to provide us with certain information such as their email address as detailed above. We use this information to create an account, provide the Service, and send you news and updates and promotional material about our products or from some of our partners. We do not share this information with third parties, except as detailed below, other than with the people/or associate working with the Service or Website. We additionally may use technologies such as cookies, beacons, tags and scripts.
Users may opt out of any unwanted emails by the unsubscribe option in the emails or by contacting us directly at [email protected].
4. Non-Personal Data Collection
We automatically collect anonymous Non-Personal Information through different technologies as described below.
Our Website may use third parties such as Google Analytics and third-party analytics, such as Facebook, Bing, Yahoo, Twitter and Mixpanel, to better understand how you use the Site and ways that we can improve your experience. Through these tools, we can see trends of usage of our Website such as total number of unique users, popular webpages or articles by number of total impressions, etc. These third parties use pixels or cookies to measure things such as the average time spent by users on the Site or visited pages so we learn how to improve the Site for you.
The performance of the Service is measured through a series of events sent anonymously to third-party services (Mixpanel) which is building aggregate data based on certain trends. Few examples of events are indicatively mentioned below:
- Connection Attempt: We collect this information to know the usage request directed to our Service on a particular hourly/daily/weekly/monthly interval, the country of origin, your SnugVPN version, etc. This metric allows us to properly adjust our infrastructure according to the demand.
- Connection Successful: We collect this information to know how many users per hourly/daily/weekly/monthly intervals successfully established VPN connections to our Service. This information correlated with the above event results is helping our engineers to determine if there are any network issues that might prevent users from starting the Service, identify peak hour intervals for our Service so we can have the infrastructure scaled to meet the requests, etc.
5. Ordering Our Service
To order our Service, you must choose which option works best for you on our pricing page. Once you click on order, you will be asked to register to create a secure account by inserting your email account. Thereafter you will be asked to choose your method of payment between credit card, PayPal and bitcoin. The specific information collected varies depending on the payment method you choose. To minimize the amount of Personal Data you submit to us, we recommend that you use bitcoin payments when subscribing to our Service.
Once you chose your selected way of payment and click “continue to payment,” you will be directed to our third-party payment gateways domain. Please make sure that you are aware that you are now on our third party payment processor’s site in order to complete your transaction. The name, address, card number, expiration date, and email address will be collected by the applicable third party payment processor to process your request. Your name and email address will be shared back with us in order for us to provide you with your subscription to SnugVPN.
6. Your Personal Data
Furthermore, we may share certain Personal Data with trusted vendors to carry out a transaction you have requested (e.g., sharing card payment information with our credit card processor to obtain payment of fees and to activate your subscription to the Service).
We may further collect and possibly share your Personal Data to enforce the Terms of Service. This may be done to prevent a crime or violation of our Terms of Service or to help solve a transgression that has been committed.
We also reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Website.
7. Your Rights and Control
Following are your principal rights concerning the protection of your Personal Data. You have the right to:
- (a) access and information which is provided to you through your account;
- (b) rectification;
- (c) erasure;
- (d) restrict processing;
- (e) object to processing;
- (f) data portability;
- (g) complain to a supervisory authority; and
- (h) withdraw consent.
If you desire to exercise certain choices and controls in connection with our treatment of your Personal Data, such as correcting, updating, deleting, opt out, or you are not able to exercise your rights through your account, please contact us at: [email protected] . In the event you make such request, note that we may require certain information from you in order to verify your identity and locate your data. This process may take reasonable time and effort. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
8. Data and SnugVPN Connection
SnugVPN has a strict no-logs Policy. We do NOT track user traffic performed inside the VPN tunnel such as browsing history, traffic destination, search preferences, data content, IP addresses or DNS queries. Therefore:
WE DO NOT KNOW AT ANY TIME WHICH USER EVER ACCESSED A PARTICULAR WEBSITE OR SERVICE. SNUGVPN IS 100% COMMITTED TO THE NO-LOGS POLICY.
9. Children’s Privacy
You represent and warrant that you are at least thirteen (13) years of age and of legal competence to use our Service. If you are under eighteen (18), please be sure to read the Agreement with your parents or legal guardians. We do not use the Service to knowingly solicit data from or market to children under the age of thirteen (13). We request that such individuals do not provide Personal Data through our Services. If you become aware or have any reason to believe that a child under the age of thirteen (13) has shared any information with us, please contact us at: [email protected]. We will take reasonable steps to ensure that such information is deleted from our files.
10. Data Retention
We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion as detailed above. Please note that unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements.
11. Policy Updates