*When the user is in normal use, we will not log any logs related to the user.
* Only when the user actively fails to connect the connection (requires the user to click the feedback button), we will collect the necessary user connection failure log.
*The connection failure log collected is limited to the success rate of our engineers to improve the VPN connection, and will not be shared with any individual or organization.
FreeYou VPN Co., Limited (“we”, “us”, “our”), we regularly collect and use information that could identify an individual (“personal data”), in particular about your purchase or use of our products, services, mobile and software applications and websites (“you”, “your”). The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements.
Please read this Policy carefully. This Policy is not intended to override the terms of any contract that you have with you or any rights you might have available under applicable data protection laws.
We may make changes to this Policy from time to time for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. We encourage you to regularly check and review this policy so that you will always know what information we collect, how we use it, and who we share it with.
1. WHO is responsible for looking after your personal data?
FreeYou VPN., Limited (“FreeYouVPN”) is a internet company focusing on internet application services. As FreeYouVPN is the company which was originally responsible for collecting information about you, it will be the data controller. You should be aware that although FreeYouVPN may be principally responsible for looking after your personal data, information may be held in databases which can be accessed by other FreeYouVPN group our affiliate companies.
2. WHAT personal data do we collect?
2.1 Personal data or information we get from your use of our product and service
We collect information about the product and services that you use and how you use them in order to properly provide the core or important features of our product and service, or to improve our product and service, or to provide additional features to our product (such as socializing functions or value-added services and promotions, etc.). Some of the typical reasons that we collect personal data include (in case of any contents herein which provide otherwise, such as Section 3 or 4, please refer to the relevant details accordingly):
Provide our product and services, including our app and related website (if any), and improve them over time;
Allow you to download and purchase products and services;
Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;
Investigate, respond to, and manage inquiries or events;
Work with and respond to law enforcement and regulators; and
Research matters relating to our prod and business, such as security threats and vulnerabilities, or conducting internal audit, data analysis, and research.
(1) Device information
We collect your UUID to allow us perform troubleshoot and analytics on our services in order to improve our product.
(2) Internet Protocol address
Device event information such as crashes, system activity, hardware settings, browser type, the date and time of your request and referral URL.
(3) Location information
When you use VPN, we may collect and process information about your actual location. We use various technologies to determine location, including IP addresses, GPS, and other sensors that may. The collection and use of location information is for enabling us to provide you better service (i.e. connect your device to the most suitable VPN server based on your location, so that you’ll have better and faster connection) and if you refuse to or stop providing it, we may not be able to provide you the best server allocation and connection. When we collect your IP address, we use it to determine user’s location for the same purpose. (We do not store or share your true IP address or use the IP address for other purposes such as associating the IP address with your browsing information or online activities when using our service.) For more details on location information, you can also find out in the following section of “Permissions on your device”.
2.3 Your information which we obtain or receive from third parties
We may obtain or receive from third parties your account information (including not be limited to account avatar, nickname etc.) which you’ve allowed them to share, and thereby binding your account at the third parties with your personal account in our product and service, and allowing you to directly log into (or by hyperlink) our account via the third party account to use our product and service. We may also, where it is allowed by applicable law or according to your agreement with third parties, obtain other types of your information from third parties.
3. WHEN do we collect your personal data?
3.1 We will collect information from you directly when you use our products and services, or where you contact us with questions, complaints or suggestions or provide us with any feedback.
3.2 We may collect information about you indirectly from other sources and combine that with information we collect through our services where this is necessary to help manage our relationship with you. These other sources may include third party software applications and social media platforms such as Facebook, Google + and Twitter.
3.3 We will not knowingly collect any personal data about persons who are legally recognized as children without making it clear that such information should only be provided with parental consent, if this is required by applicable laws. For the purpose of this Policy, “children” refer to persons under the age of 16 (in the laws of some countries, this age limit maybe higher, in such case such age limit will apply to those subject to such laws).
We’ll comply with local laws regarding children’s right protection applicable to our product and service. FreeYouVPN will only use the personal data of children as far as is permitted by law where the required parental or guardian consent has been obtained. If you believe we have collected information from any child in error or have questions or concerns about our any other practices relating to children, please notify us and we will take proper actions to investigate and promptly solve relevant issues In case we find out that we’ve collected children’s information without prior consents from their lawful guardians, we’ll make efforts to quickly delete relevant data.
4. What PURPOSES do we USE your personal data for?
We will use your personal data:
To keep you posted on software updates, technical updates, security alerts and support and administrative messages;
To allow you to download and purchase our products and services such as our apps and related websites;
To help us create, provide, develop, operate, deliver, maintain and improve our products, services, content, advertising and continually improve your user experience;
To assess customer satisfaction and link or combine with information we get from others to help understand your needs and provide you with better user experience;
To process transactions and send you related information, including confirmations and invoices;
To respond to your comments, inquiries, questions, provide customer service and support and fulfill your requests;
To verify identity, assist with identification of users, and to determine appropriate services;
To communicate with you and send you important notices or personalized messages, such as communications about purchases and changes to our terms, conditions, and policies;
To monitor, evaluate and analyze trends, data, transactions, usage and activities in connection with our products and services;
To facilitate internal purposes such as auditing, data analysis, and research to improve our products, services, and customer communications;
To detect, investigate and prevent fraudulent transactions and other illegal activities and protect our rights and property;
To use your personal data for purposes associated with our legal and regulatory obligations.
We have to establish a legal ground to use your personal data, so we will make sure that we only use your personal data for the purposes set out in this Section 4 where we are satisfied that:
our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfill obligations under the contract signed between you and us), or
our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we are subject to, or
our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), provided it is always carried out in a way that is proportionate, and that respects your privacy rights.
In order for us to provide you with our services when you use certain applications, we may collect special categories of data from you. For our collection or use of your special categories of data, we will establish an additional lawful ground to those set out above which will allow us to use that information. This additional exemption will typically be:
your explicit consent;
the establishment, exercise or defense by us or third parties of legal claims; or
a specific exemption provided under local laws of EU Member States and other countries implementing the GDPR, or other laws of jurisdictions which are applicable to our handling of your personal data.
PLEASE NOTE: If you provide your explicit consent to allow us to process your special categories of data, you may withdraw your consent to such processing at any time. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent we will tell you more about the possible consequences.
PLEASE NOTE: We will not need to, or will be effectively unable to, get your prior consent on collecting and / or using your personal data in the following circumstances, so far as these exemptions are allowed under applicable laws and so far as the collection and usage is necessary for such purposes:
when the collection and usage is related to national secure or national defense, public safety, public health or significant public interests;
when the collection and usage is related to investigation, prosecution, trial or judgment enforcement of criminal acts;
for the sake of life, property or other major legitimate interests of you or others, while in such incidents we have difficulty to reach you to confirm your consent;
when the information we collect has been voluntarily disclosed by yourself;
when we collect your information from sources that have made legitimate and public relevant disclosures of such information, such as legitimate news reports, or governmental information disclosure;
when relevant collection or usage is necessary for ensuring the safe, stable and legitimate operations of our product and service, such as when we need to diagnose or deal with failure or defects in our product and service;
when the collection or usage is required for legitimate news reports;
when the collection or usage is necessary for academic or research institutes to make statistical or academy research for public interests, and when such results of research are being disclosed, the personal data contained has been made to be “de-identified”;
when the collection or usage of your information is permitted by applicable laws and regulations for other reasons.
5. Who do we SHARE your personal data with?
We may share your data with other FreeYouVPN affiliate companies in or outside Europe. We may also share your data with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data. These third parties may include:
Our regulators, including regulators and law enforcement or investigation agencies in the E.U., U.S., China, and around the world;
Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues (such as cyber-attack, or other illegal or immoral acts), targeting at or related to protecting against harm to the rights, property or safety of our users or us, our affiliates, employees or the public;
Solicitors and other professional services firms (including our auditors).
Also, if we were to sell part of our businesses or assets, as required by applicable laws or agreed with relevant parties, we would need to transfer your personal data to the purchaser in case of carrying out relevant deals such as merger, acquisition or asset transfers.
6. Direct marketing
We may use your personal data to send you direct marketing communications about our own or third party products and services or our related services including our latest product announcements and upcoming events. This may be in the form of email, post, SMS, telephone or targeted online advertisements. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.
For the purposes of GDPR our processing of your personal data for direct marketing purposes is based on our legitimate interests (as further detailed in applicable Appendix), but where opt-in consent is required by the relevant laws such as the Privacy and Electronic Communications Regulations of Europe, we may ask you for your consent. You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out or unsubscribe links in electronic communications (such as emails), or by contacting us using the details in Section 12 if you find problems in making such settings by yourself. Please also note that, when necessary (e.g., certain service is suspended due to system maintenance), we may send to you relevant announcements. You may not be able to cancel the announcements related to the services that are not promotional in nature.
We also use your personal data for customizing or personalizing ads, offers and content made available to you based on your usage of our mobile applications, websites, platforms or services, and analyzing the performance of those ads, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits. This constitutes “profiling” in respect of which more information is provided at Section 8 of this Policy.
7. International transfers
We may transfer your personal data to FreeYouVPN affiliate companies or service providers that are located inside or outside of Europe. We may also share your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:
we will only transfer your personal data to countries which are recognized as providing an adequate level of legal protection; and
transfers to FreeYouVPN affiliate companies, service providers and other third parties will always be protected by contractual commitments for additional security. For example, the EU–US Privacy Shield for the protection of personal data transferred to the US.
You have the right – as allowed under applicable law – to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out in Section 12 if you would like further information (which may be redacted to ensure confidentiality).
“Automated decision making” refers to a decision which is taken though the automated processing of your personal data alone. This means processing using, for example, software code or an algorithm, which does not involve any human intervention. As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
If you are a consumer that has signed up to receive marketing updates, we may use profiling to ensure that marketing materials are tailored to your preferences and to what we think you will be interested in. This does not have any significant effect, or a legal effect on you. In certain circumstances it may be possible to infer certain information about you from the result of profiling, which may include special categories of data. We will not however conduct profiling based on your special categories of data unless we have obtained your explicit consent to do so.
PLEASE NOTE: You have certain rights in respect of automated decision making, including profiling where that decision has significant effects on you, including where it produces a legal effect on you. See Section 10.
9. How long do we keep your personal data?
We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 4 and relevant Appendixes of this Policy. In some circumstances we may retain your personal data for longer periods of time, for example where we are required to do so to meet legal, regulatory, tax or accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings. Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
10. What are your rights?
You have a number of rights in relation to your personal data. In summary, you may request access to your data, rectification of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. You also have the right to complain to your supervisory authority (further details of which are set out in Section 12 below).
As demanded, FreeYou VPN is completely devoted to protect privacy of the users. Described below is the information we collect and how they are used by us. Additionally, we declare that we do not collect nor store any activity logs in any kind (either browsing and data content or DNS queries). Please read this page to understand how the minimum possible data is collected solely to improve our services and technical performance. Gathering such information is exclusively for providing aptitudes such as personalization services, interactive communications, online shopping, and personalized communication. We also use the information to estimate the size of our audience and measure certain traffic patterns to track the progress and number of entries in our promotions and contests, to track visits to and business conducted at our online store, and also to notify our visitors about updates to our website and system statuses.
Personal information:To provide and dispense our services we require your name, email address, and payment information to create your subscription. Payment information is used for processing service orders, renewals, cancelations, fraud checking. Note that we do not store credit card details and we do not process payments directly. All payments will be carried out via third party payment platforms.
Diagnostic and connection summary: Include anonymous reports based on minimum required data about application performance, Speed test data, connection diagnostics, and crash experiences. We retain last 20 connection records (time, duration, country, unit model, and the running version of application) for a certain limited time and temporarily just to recognize possible concerns regarding the connectivity and provide satisfactory support. FreeYou VPN does not maintain user’s physical location or IP addresses.Furthermore, once the App is activated, users would be asked if they prefer to share these data with us. Users are able to activate or deactivate diagnostic data sharing at any time in the App’s settings menu. For iOS users ,Apple’s crash reporting can be turned off in iOS settings.
Active sessions information : To check the total of connected devices at the same time from single account.
Correspondence information :We preserve all the conversations that occur between our customer service and users depending on how we communicate.
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Data sharing declaration
FreeYou VPN does not sell, rent, or trade user personal information with anybody or any third-party entity.
Consent and Age Restrictions