This Privacy Policy (the “Policy”) describes how Upstate Media Inc (“we”, “us”, the “Company”) collect, use, disclose and protect our users’ (“you”) information.
This Policy applies to all services(collectively as the “Service”) offered by Upstate Media Inc, including VPNify software applications (Windows, Mac, Android, iOS, Linux, Chrome Extension)
Please acknowledge that it is your responsibility to review this Policy as we may update the Policy from time to time. In the event of modification of the Policy, we may contact you via email, in-app message, and notification regarding the changes in the Policy, if you have permitted us.
- DATA WE DO NOT COLLECT
We want to start this off by addressing the information we do not collect to offer better clarity for our users.
WE DO NOT COLLECT:
How you utilize VPN connection. We do not see the applications, service or websites you use while connected to our Service nor do we store them.
Original IP address and server IP address (that you connected to).
DNS Queries
- DATA WE COLLECT
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.
The following data have been break down into different categories to help you better understand what information we collect, how we collect it, and why do we collect it:
ACCOUNT DATA
Registration date (e.g., 2019/09/01; this information is automatically collected during account registration.)
Subscription status (e.g., 2019/09/01 – 2019/10/01; this information is automatically collected when users make the purchase.)
Payment method (e.g., iTunes; this information is automatically collected when users make the purchase.)
Advertising data (e.g., iOS ad identifier – IDFA), Android ad master identifier)
We collect these account information strictly for the user support purpose.
PAYMENT DATA
Transaction ID (or reference ID) (e.g., UHK52651RSA; this information is automatically collected when users make the purchase.)
Geolocation & Timestamp (e.g., US, 2019/09/01 07:05; this information is automatically collected when users make the purchase.)
Cardholder last name (e.g., Huey; this information is automatically collected when users make the purchase.)
Last four digits of the Credit card (e.g., 0009; this information is automatically collected when users make the purchase.)
This information is collected on the third-party payment processing system automatically, and it is separated from our internal system. This information is used for user support and troubleshooting purposes only. We have a dedicated accounting team process payment related-issue.
AGGREGATED DATA
Operating system (e.g., iOS 11.3.1-10,000,000; this information is collected when the user open VPNify app.)
App version (e.g., Version 6.1_132_432908b; this information is collected when the user open VPNify app.)
Daily active user (e.g., 2018/09/01-19,000,000; this information is collected when the user open VPNify app.)
Total data used for the month (e.g., 2019/09-1000TB; this information is automatically calculated and collected at the end of the month.)
User geodemographics (e.g., US-100,000,000; this information is provided by the App store & the Google Play store.)
This information helps us to understand our user better and in product planning, to further improve the user experience and user satisfaction.
VPN CONNECTION DATA
Server location(e.g., US-New York server 1; this information is automatically collected during VPN connection.)
Connection timestamp (e.g., Connected@05:20 2019/09/15; this information is automatically collected during VPN connection.)
Error report (e.g., Error_Userdoesnotallowconfiguration; this information is automatically collected when VPN connection failed due to error.)
Choice of the protocol (e.g., Protocol_A; this information is automatically collected during VPN connection.)
Network type (e.g., 4G; this information is collected when users send us the “Network analysis” report, which helps us to determine the cause of connection issues.)
This information is used for troubleshooting, VPN service optimization ONLY, all the information WILL BE AUTOMATICALLY ERASED PERMANENTLY from the system after 96 HOURS.
OTHER INFORMATION
Analytics data (e.g., App crash report, in-app page engagement; this information is collected when using the VPNify.)
Advertising data (e.g., iOS ad identifier – IDFA), Android ad master identifier)
This information helps us to track the performance of the app and certain features and to provide the necessary support to sustain our free VPN service, please note that we do not share your share the information that you provide to VPNify with the third party advertisers. However, advertisers may be able to collect certain information independently from you or your device when serving ads from the VPNify, including your device’s advertising ID.
You may find more information about the advertisers and analytic service providers:
Adjust: https://www.adjust.com/privacy-policy/
AdMob: https://policies.google.com/privacy
Google Analytics, Firebase, GCM: https://policies.google.com/privacy
Applovin: https://www.applovin.com/privacy/
Mopub: https://www.mopub.com/legal/privacy/
Facebook: https://business.facebook.com/privacy/explanation
Smaato: https://www.smaato.com/privacy/
Appsflyer: https://www.appsflyer.com/product/data-privacy/
Branch.io: https://branch.io/gdpr/
Mixpanel: https://mixpanel.com/legal/privacy-policy/
- HOW WE SHARE YOUR DATA
We use third-party live chat tool Intercom to communicate and interact with you. We only provide the intercom the unique device id & user id which is hashed from the IDFA or Android ad master identifier. This is information is encrypted and secure and is used for user support purposes.
You may find more about the privacy policy of intercom here: https://www.intercom.com/terms-and-policies
4.OUR COMMITMENT TO PRIVACY PROTECTION
We are committed to protecting our users’ privacy and put it into several practices:
The support team and accounting team have limited access to the data respectively(e.g., The support team can only access account data while accounting team can only access payment data through third party payment processors).
The VPN connection data in our system will be permanently erased 96 hours after it is collected.
We have designated staff regularly review the relevant regulation, rule, law changes to enforce privacy protection. For requests or inquiries concerning user privacy, feel free to contact us at [email protected], our designated staff will respond to requests or inquiries within 48 hours.
- COOKIE POLICY
We use cookies to help us provide better services on our websites. To break it down, we use three kinds of cookies on our website:
Session cookies: These cookies store your preference, logins on our site.
Google Analytics: We use this service to track the performance of certain pages on our site and to understand the impact of our advertising campaign. Google Analytics reference link: https://policies.google.com/technologies/types
Intercom: We use this service for live chats. Intercom reference link: https://www.intercom.com/terms-and-policies#cookie-policy_why
You may change your browser or devices’ setting to disable or refuse certain cookies on our site. Please do note that disables certain cookies may result in inaccessibility of our services on the websites.
- GDPR COMPLIANCE
In compliance with the GDPR (General Data Protection Regulation), all users subject to the GDPR have rights in relation to the personal data:
You have the right to be informed regarding what data does VPNify collect, as you are reading this Policy.
You have the right to be provided with a copy of the data we collect from you upon request. Please do note that this may take up to 30 calendars days to complete.
You have the right to request us to correct any information about you that may be incomplete or inaccurate.
You have the right to request us to delete the information that we have about you. Do keep in mind that this may not apply to some payment information as per tax law we are required to retain certain information.
You have the right to request us to suspend processing your personal data.
You have the right to be provided with a copy of the data we collect from you in common format upon request(e.g., to reuse the data for your own purpose). Please do note that this may take up to 40 calendars days to complete.
You have the right to object to us processing your personal data.
You have the right to be informed in relations to the profiling or any automated decision making.