At VPN Proxy Pro, LLC (“TouchVPN”, “we”, “us”, or “our”), a Pango Group company which is owned
and operated by Pango, we believe it’s important
that everyone, regardless of their situation,
can obtain secure and private access to the internet. We always aim to provide this access
without compromising the privacy of our customers.
This Privacy Policy describes TouchVPN’s privacy practices across all of our products, services,
apps, and websites that link to this policy (we refer to these collectively as our “services”).
See the Contact Us section below for more information about TouchVPN and contact details.
Product Privacy Notices
Certain TouchVPN services may process data differently or in additional ways compared to other
services that we note in Product Privacy Notices specific to such services, in product documentation,
or inside products themselves at places where such information is relevant. Please refer to these
Products Privacy Notices to better understand our privacy practices for each product:
1. VPN Product Privacy Notice
1. What Information Do We
Collect About You?
- This section describes the various categories of personal data (aka ‘personal information’) we collect
from and about you. This information is not collected in all situations, but only in specific
product-specific
situations. For example, as noted in our VPN Products Privacy Notice, our VPN services only collect a
limited
amount of personal data, and specifies that the browsing history associated with any websites or apps
visited
during a VPN session are not connected to any customer information, unless the customer provides their
identity
and associated information as part of a customer support request.
1.1. Information You Provide to Us
-
Account Information. Some services require, or allow you to create, an account before you can access them.
As part of registering for an account, we may collect information such as your name, username, email
address,
and password.
-
Billing and Payment Information. In order to purchase a service, you may need to provide us with details
such
as billing name, billing contact details (street addresses, email addresses), and payment instrument
details.
Our payment processing partners process this basic billing information for payment processing and refund
requests.
-
Communications and Submissions. You may choose to provide us with information when you communicate with us
(e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out
an
online form, respond to surveys, provide feedback, post comments to our website, participate in promotions,
or
submit information through our services.
1.2. Information collected when you use our services
-
Usage information. We collect information about how you interact with our services, including when you visit
and
use our websites or apps, including which TouchVPN web pages or app features are used, and when and for how
long
you use our services. We may use cookies and/or other technologies to collect this information. See below
for more
information.
-
Device information. We collect information from and about the device you use to access our services,
including about
the browsers and TouchVPN apps you use to access our services. For example, we may collect device or mobile
advertising
identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and
other network
information (such as internet service provider name, carrier name and signal strength), and application
version numbers.
We may use cookies and other technologies to collect this information. See below for more information.
-
Diagnostic information. We may collect information about the nature of the requests that you make to our
servers,such
as what is being requested, information about the device and app used to make the request, timestamps, and
referring URLs.
Location information. Unless otherwise expressly stated or with your consent, we do not collect your
location information
based on your device’s GPS or other device sensor data. However, we may collect your approximate location by
calculating
an imprecise latitude and longitude based on your IP address to provide you with better service (e.g. to
connect you to
the nearest and fastest VPN server).
-
VPN-Specific Information. Our VPN products do not log any information that associates your account
credentials or identity
with your VPN session activity. We do not maintain any records that show what websites you were browsing or
apps accessed
through a VPN connection. However, we will;
- Record the amount of bandwidth used in a VPN session
- Identify the locations of the VPN servers utilized
- Collect similar diagnostic information as referenced above.
-
Ask you to rate your connection and provide some more detailed survey information if you are not
satisfied with the service.
This information is not tied to a specific user.
-
We may also assign your device a ‘hash’, which is a random ID generated when you first launch one of our
VPN apps. Device
hashes are not linked to VPN browsing activity or user identity, but may be used to measure individual
user activity.
See the VPN Products Privacy Notice for more information.
1.3. Information Provided to Us by Third Parties
-
If you are invited to use an TouchVPN service, the person who invited you may submit your personal data,
such as your email
address or other contact information.
-
Third Party Accounts. Some services may allow you to register an account using a third party account (such
as a Google or Microsoft
account). If you do so, that third party may send us some information about you that they have. You may be
able to control what
information they send us via your privacy settings for that third party account.
-
Threat Information. We receive information from reputable members of the security industry who provide
information to help us to
provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists,
phone number blacklists,
and sample malware). Some of this information may contain personal data on an incidental basis.
2. How Do We Use Your Information?
We use the information we collect for various purposes described below. For visitors from the European
Economic Area (EEA) or U.K.,
please also note our lawful basis for each processing activity below;
-
To provide, maintain, troubleshoot, and support our services. We use your information for this purpose on
the basis that it is
required to fulfill our contractual obligations to you. Examples include;
-
For our VPN products, using information about how much bandwidth you use and how long you use our
services in order to
provide the services in accordance with a plan to which you have subscribed;
- For our digital threat platform; using threat and device information to determine whether certain
items pose a potential security threat; and
- Generally to ensure the proper functioning of our services.
- For billing and payment purposes. We use your information in order to perform billing administration
activities and process payments, which are required to fulfill our contractual obligations.
-
To communicate with users and prospective users. We use your information to communicate with you, including
by responding to your requests, and sending you information and updates about our services.
We may do this in order to fulfill our contract with you, because you consented to the communication, or
because we have a legitimate interest in providing you with information about our services.
-
To improve our services. We want to offer you the best services and user experiences we can, so we have a
legitimate interest in continually improving and optimizing our services. To do so, we use your
information to understand how users interact with our services. Examples: we analyze certain usage, device,
and diagnostic information to understand aggregated usage trends and user engagement with our
services (and, for example, invest in technical infrastructure to better serve regions with increasing user
demand); we may use device and threat information to conduct spam, threat, and other scientific
research to improve our threat detection capabilities; we review customer feedback to understand what we
could be doing better.
- To develop new services.We have a legitimate interest in using your information to plan for and develop
new services. For example, we may use customer feedback to understand what new services users may want.
-
To market and advertise our services. We may use your information to provide, measure, personalize, and
enhance our advertising and marketing based on our legitimate interest in offering you services that may be
of interest. Examples: we may use information such as who or what referred you to our services to understand
how effective our advertising is; we may use information to administer promotional activities such as
sweepstakes and referral programs. Note that our VPN products do not use your VPN browsing activity for
these purposes and we do not maintain any records that show what you were browsing or accessing through a
VPN connection.
-
To prevent harm or liability. We may use information for security purposes (such as to investigate security
issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal
obligations,
to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or
liability to TouchVPN and our users. For example, we may use account, usage, and device information to
determine if
an entity is engaging in abusive or unauthorized activity in connection with our services.
-
For legal compliance. We may use your information as required by applicable law, legal process, or
regulation. We may also be compelled by a contract or court to provide certain information necessary to our
business
partners in order to fulfill the terms of a business agreement. To learn about our practices regarding
sharing your information with third parties for legal compliance purposes, see Section 3.1 below. We also
use your information
to enforce our legal rights and resolve disputes.
3. Who Do We Share Your
Information With and Why?
3.1. In General
We may disclose your information in the following circumstances:
- In accordance with your instructions or consent. For example, some services may allow you to register an
account using a third party account (such as a Google or Microsoft account). If you choose to do so, we will
share information
with the third party account provider.
-
To your business organization (for our business services). If a business customer is providing you with
access to our services through a business account, others in that organization may be able to see and manage
the information necessary
to maintain your account and the personal contact information associated with it (such as an administrator).
Please note the following details about information shared as a result of these relationships;
- Business organizations do not get access to, or receive any reports from, any network or Internet
usage information related to your VPN activity.
-
Business organizations do not receive any information our identity products provide to you, such as
information associated with your credit report, credit alerts, or other identity-related information
unless you provide them with express
consent for any such use in each instance of their request.
- For collaborating with others on your behalf. Some services may provide ways for different users to
interact or collaborate with each other. Your information will be shared in connection with those activities
if you choose to engage in them.
-
Vendors and service providers. To help us provide some aspects of our services, we work with trusted third
parties and partners (including affiliated companies in the Pango Group). To protect your
data, we enter into appropriate
confidentiality and data processing terms with these third parties, review their security practices, and
limit information sharing to the scope of what they are helping us with. Examples of activities that third
parties help us with include:
- processing customer payments, e.g. Intersections, LLC
- providing analytics about our services
- providing sales and customer support
- maintaining the infrastructure required to provide our services
- delivering our marketing and advertising content. However, please see below for more information about
the advertising services that support our Free VPN Products.
- To a new owner of TouchVPN or any of our assets. If ownership or control of all or part of our services,
assets, or business changes, we may transfer your information to the new owner.
-
Aggregated or de-identified data. We may use and share aggregated data and data that is de-identified such
that it no longer reveals the identity of an individual user for regulatory compliance, research and
analysis, our own marketing and
advertising activities and other legitimate business purposes.
-
To comply with legal process and the law we may share your information if we are required to do so by
applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid
law enforcement requests relating
to a criminal investigation, or alleged or suspected illegal activity that may expose TouchVPN, you, or any
of our other users to legal liability. If we share your information for these purposes, we limit the
information shared to what is legally
necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
To reiterate, our VPN products do not collect information about which websites you visit or apps you use, so
this information is not accessible
in a law enforcement request.
-
To enforce our rights and prevent fraud and abuse.We may share limited amounts of your information to
enforce and administer our agreements with customers and users, and to respond to claims asserted against
TouchVPN. We may also share your information
in order to protect against fraud and abuse against TouchVPN, our affiliates, users and others.
3.2. Cookies and Other Tracking Technologies
TouchVPN uses various technologies in our services to help us collect
website or app user information. These technologies include:
-
Cookies. Cookies enable TouchVPN or third parties that we allow to set cookies on your device to recognize
visitors to our websites. For more information on how we use cookies, please review the cookie notice
associated with each product website indicated below. We use cookies:
- To provide our services. Some cookies are essential for the proper operation of our services. For
example, cookies allow us to authenticate who you are and whether you’re authorized to access a
resource.
- To store your preferences. Cookies can store your preferences, such as language preferences or whether
to pre-fill your username on sign in forms. We may also use them to optimize the content that we show to
you.
- For analytics. Cookies are used to inform us how users interact with our services so we can, as a
legitimate interest, improve how they work (such as what screens or webpages you access, and whether our
advertising is effective).
- For security. Cookies can enable us and our payment processors to detect certain kinds of fraud.
- For TouchVPN’s advertising-related purposes. We advertise our services online with the help of third
parties who show ads and marketing about us on sites around the internet.
-
Pixel Tags / Page Tags / Web Beacons / Tracking Links. These tools allow us to determine if you perform a
specific action on a web page or email message. When you access a page, ad, or email, or click a link, these
items let us know that you have accessed that page, opened
an email, or clicked a link. They may also indicate your Internet Protocol (IP) address, which enables
TouchVPN to determine your approximate geographic location as assigned by your Internet Service Provider.
- Software Development Kits (SDKs). This mobile app software is provided by our business partners that
enables our mobile apps to interact with the services those partners provide. See below for more information
about how we use SDKs with our Free VPN products to provide advertising services.
Your Choices With Our Use of Cookies
-
TouchVPN collects certain information by automated means when you interact with our website. Like many
companies, TouchVPN uses various technologies including “cookies” and related technologies such as pixel
tags on our website to help us collect certain information. Our Service Providers
(such as analytics providers) may also place cookies and similar technologies on our website. For more
information on TouchVPN website’s use of cookies, visit the privacy or cookie-specific notices here.
-
You have the ability to manage your cookie preferences in your web browser settings, including deleting
cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your
browser to understand what controls it gives you over cookies. Note that deleting
or blocking certain cookies could adversely impact the proper operation of our services.
-
Industry Advertising Choices: For information on how to opt out of personalized or interest-based
advertising from select advertising partners on our website, you can visit the following pages:
4. Use of
Advertising Services With Free VPN Products
For users of the free version of our VPN product, we may serve ads through the use of third-party advertising
services indicated below.
As previously noted, neither TouchVPN nor any third-party advertising service has access to the VPN browsing
information, such as the websites
you visit or apps you use while in a VPN session. However, as with any online advertising service, the
entities will have access to the information
associated with the ad delivery such as which website or app the ad was delivered to, and the device-specific
information listed below.
In order to display ads in our apps, we may utilize third-party software development kits (SDKs), which
consists of software code provided by
a third party and embedded into our apps. These SDKs may collect the following information from your device or
use;
- Device or mobile advertising identifiers (controlled by your mobile operating system)
-
Internet Protocol (IP) Address, which may reveal your approximate geographic location as determined by your
carrier or ISP. However, when using the VPN service,
this may replace your actual location with an alternative geographic location.
- Device-specific information such as make, model, OS version, language, time zone and other information.
- The name of the app or website serving the ad.
As some of the ads may be personalized based on your mobile advertising identifier or IP address, you may see
an AdChoices icon on an ad. You can click this icon
to learn more about the ad network that provided the ad, its privacy policy, and your choices regarding opting
out from any personalized advertising. If you
opt out from personalized advertising, you may still see non-personalized ads. While we request you not to use
ad blockers to prevent the display of ads because
that is how we support our free services, our services are able to continue functioning if you do use ad
blockers.
We use the following advertising services to provide ads with our free VPN
products:
Company
Privacy Policy or Opt-Out
In addition, you may opt-out of interest-based mobile advertising by utilizing the
Digital Advertising Alliance (DAA)
AppChoices app.
5. Security
TouchVPN employs a range of administrative, organizational, technical, and physical safeguards designed to
protect your data against unauthorized access, loss, or modification. Access
to your Account Information and Services Information is restricted to our employees who require such access to
perform their job functions. While our controls are strong, no data security
measures can guarantee 100% protection.
6. International Data Transfers
TouchVPN may transfer your personal data to countries other than the one in which you reside. We do this to
facilitate our operations, and transferees include
other TouchVPN companies, service providers, and partners. Laws in other countries may be different to those
that apply where you reside. For example, personal data collected within the U.K.,
Switzerland or the European Economic Area (EEA) may be transferred and processed in the United States for
purposes described in this policy. However, we put in place appropriate safeguards that
help to ensure that such data receives an adequate level of protection, which typically includes TouchVPN and
corporate recipients executing the Standard Contractual Clauses (aka ‘Model Contracts’)
adopted by the European Commission or UK for such transfers to the U.S. You may contact us if you would like
more information about such safeguards.
If you change your country of residence, the TouchVPN company responsible
for your data may change accordingly, and your data may be transferred to that other company.
For users of our VPN products, if you are a UK or EEA resident and you
choose to use our software to route your Internet traffic through servers in countries not deemed ‘adequate’
by the UK or EEA,
then you acknowledge that such transfers are executed at your direction and with your unambiguous consent.
7. Data Retention
With respect to our VPN products, TouchVPN does not collect or retain data about your browsing activity while
you are connected to the VPN Services. TouchVPN generally retains your personal information for as
long as is needed to provide the services to you, or for as long as you have an account or subscription with
us. We may also retain personal information if required by law, or for our legitimate interests, such
as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data
may be stored in backup systems for a limited period as a security measure to protect against data loss.
For more information on the information stored, visit our VPN Products Privacy Notice.
8. Your Rights
Depending on your country of residence, you may have certain legal rights in
relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable
law, these may include the right to:
- access and receive a copy of your personal data;
- correct your personal data;
- restrict the processing of your personal data;
- object at any time to the processing of your personal data;
- have your personal data erased;
- data portability;
- withdraw any consent you previously gave to the processing of your data (such as opting out to marketing
communications);
- lodge a complaint with a data protection authority;
-
request that we provide you with the categories of personal data we collect, disclose or sell about you; the
categories of sources of such information; the business or commercial purpose for collecting or selling your
personal data; and the categories of
third parties with whom we share personal data. This information may also be provided in this Privacy
Policy.
You may be able to exercise some of these rights by using the settings and tools provided in our services. For
example, you may be able to update your user account details via the relevant account settings screen of our
apps.
You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or
“unsubscribe” link in such communications.
Some mobile and web browsers transmit "do-not-track" or “opt-out preference” signals. We currently do not take
action in response to these signals. Otherwise, if you wish to exercise any of these rights, you may contact
us using the details in the “Contact Us”
section below. As permitted by law, we may ask you to verify your identity before taking further action on
your request. You may also be permitted to designate an authorized agent to submit certain requests on your
behalf. If you do so, you must give the authorized
agent written permission to make such requests, or a power of attorney. We may also follow up with you to
verify your identity before processing the authorized agent’s request.
9. Your California Privacy Rights
The above information includes the categories of personal information TouchVPN collects, processes and shares
with service providers and other businesses. If you would like to exercise your rights to receive the specific
pieces of information,
or other rights indicated above applicable to you, please refer to the ‘Contact Us’ section below.
TouchVPN does not ‘sell’ or ‘share’ personal information for our own monetary benefit. However, as the CCPA
defines ‘sell’ and ‘share’ broadly, some of the advertising services that support our website, marketing
efforts, and mobile
applications use third party advertising services that may be deemed a ‘sale’ or ‘sharing’ under California
Law. Please visit TouchVPN’s cookie policy page to see the list of cookies, cookie notices, or app-specific
advertising services
to indicate your continued preferences to receive such personalized ads.
10. Age Restrictions
Our services are not intended for and may not be used by minors. In this context, minors are individuals under
the age of 16 except for our identity and credit monitoring services,
which are restricted to those under the age of 18. TouchVPN does not knowingly collect personal data from
minors or allow them to use our services. If we discover that we have collected
personal data from a minor, we may delete such data without notice. Please note that the legal terms under
which we make certain services available may require users to be older than 16 years of age.
11. Privacy Policy Updates
TouchVPN may update this Privacy Policy from time to time in accordance with this section for reasons such as
changes in laws, industry standards, and business practices. TouchVPN will post updates
to this page and update the “Last updated” date above. If we make updates that materially alter your privacy
rights, we will also provide you with advance notice, such as via email or through the services.
If you disagree with such an update to this policy, you may cancel your services account. If you do not cancel
your account before the date the update becomes effective, your continued use of our services
will be subject to the updated Privacy Policy.
12. Contact Us
We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy
practices. If you would like to exercise your rights,
have any questions or complaints about our privacy practices, you can contact us using the following details:
For visitors from the UK or EEA, the GDPR gives you additional rights to
contact our Data Protection Officer (DPO). The TouchVPN has appointed Bird & Bird DPO Services SRL as a DPO
for TouchVPN and its services, and may be reached:
- by using the following email: [email protected]
- by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels,
Belgium
Archived Versions
July 31,2023
