Privacy Policy

Last updated May 20, 2020

Preface

You have legitimate concerns about privacy and therefore we expressly describe all processing of personal data done by us. We want you to understand what limited information we collect and what may happen to that information when you use any of the FlyVPN Services.

This document (hereinafter – the 'Privacy Policy' ) explains the privacy rules applicable to all information collected or submitted when you access, install or use the FlyVPN Services.

By visiting FlyVPN website, by submitting your personal data to FlyVPN, also by accessing, installing and/or using the FlyVPN Services you confirm that you have read this Privacy Policy and that you enter into legally binding relationship with FlyVPN (hereinafter – 'we' , 'us' , 'our' or 'FlyVPN' ), as well as you agree to be bound by this Privacy Policy. If you disagree with the rules of this Privacy Policy, please do not use the FlyVPN Services.

If you have any questions about this Privacy Policy or your privacy, please contact us by email support@flyvpn.com

Processing of your data

FlyVPN processes user data only to a very limited scope – only as much as it is absolutely required for provision of the FlyVPN Services, processing of payments for the FlyVPN Services, as well as functioning of the FlyVPN website and mobile applications.

Personal data is processed by FlyVPN automatically and manually. Unless expressly noted otherwise, FlyVPN or a designated subsidiary in your country shall act as the responsible personal data controller for any data processed. FlyVPN uses third party data processors only for processing of payment data, emailing service and basic website and app analytics.

Anyone may browse our website, install FlyVPN application and mobile applications without signing up for the FlyVPN Services, however the functionality of the FlyVPN Services will be very limited or absent. If you want to engage full functionality of the FlyVPN Services, you need to create a user account and provide basic personal data indicated below.

If you choose to create a FlyVPN Account, you must provide the following basic information:

Email address.
We require that you provide personal information, such as an email address, in order to establish an FlyVPN account, and so that we can email you, and respond to support queries that you initiate.
FlyVPN uses your email address for the following reasons:
To send emails related to payment transactions.
To send verification email when registering an account.
To send you updates and announcements.
To communicate with you about your VPN services or respond to your communications.
To send marketing information, such as FlyVPN offers, surveys, invitations, and content about other matters in connection with FlyVPN (“Marketing emails”). You may choose to not receive Marketing emails by following the opt-out procedure described in these emails.
FlyVPN uses your personal information only for the purposes listed in this Privacy Policy, and we do not sell your personal information to third parties.

Payment data.
With some forms of payment, the Site may redirect you to the website of a third-party payment processor (namely PayPal, Alipay, Mycard, Payssion or Paymentwall) to complete the transaction. To understand what personal information these processors collect and store, please refer to the respective processor's terms and privacy policy.

The specific information collected varies depending on the payment method you choose. To minimize the amount of personal information you submit to us, we recommend that you use Bitcoin payments when subscribing to our Service.

You must maintain this information current, truthful, complete and accurate. You warrant that you are authorized to provide such information. You authorize us to verify your information at any time. If it is found to be untrue, inaccurate, not current or incomplete, we retain the right, in our sole discretion, to suspend or terminate your user account and your access to the FlyVPN Services.

In order to maintain the VPN service, the FlyVPN also processes limited technical information, which sometimes may be considered personal data. This information is used for improving the functionality and usability of our website and FlyVPN Services. If you decide not to provide this limited information, we may not be able to provide you with the full scope of the FlyVPN Services. Said information may also include:
Server load information.
We monitor the server performance in order to recommend the most suitable servers to our customers.
Customer service information.
FlyVPN stores inquiries and communications with users through the Contact Us.

Cookies and Mobile Identifiers

What is a cookie?
A cookie is a small text file used to store information about your visit to the Site. Cookies let FlyVPN optimize and improve the user experience of the Site by helping us deliver certain functionalities, such as website login and language settings. The cookies we use may vary over time as we continuously update and improve our Site.

Disabling cookies
You are free to change your cookie preferences at any time. You can do this in the settings panel for your browser. Depending on which browser and device you use, you may be able to control which cookies you allow, which cookies you want to block in the future, and delete cookies. For more information about these settings, please refer to the “help” section of your browser.
Please note that choosing to disable cookies may negatively affect some of the features that make your Site experience more efficient.

FlyVPN's cookies
The cookies set by FlyVPN enable us to set your language preference, attribute visitors to a marketing channel, and, once you log in, securely show you information that is specific to your account. The cookies contain a user identifier, but no directly personally identifying information such as your name or email address, and do not track any activity outside of FlyVPN's domains.

Third-party cookies
FlyVPN uses third-party services such as Google Analytics and Adwords. Cookies from such services are used to collect data for statistical reports. For example, we may generate reports regarding the amount of time users spend on the Site and the number of users who visit a particular page.

FlyVPN uses Google AdWords remarketing to show advertisements on third-party websites (including Google) to users who have visited our Site. We may show such users advertisements on a Google search results page, or on a site in the Google Display Network.

Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to the Site. Any data collected will be used in accordance with our Privacy Policy and Google's privacy policy. Users may opt out of Google's use of cookies by visiting the Google Advertising Opt-out Page. Users may opt out of Google Analytics by visiting the Google Analytics Opt-out Page. Users may opt out of third-party vendor use of cookies by visiting the Network Advertising Initiative Opt-out Page.

Mobile identifiers
A mobile identifier is an identifier provided by an Android or iOS device. It does not contain your name or email address. FlyVPN uses mobile identifiers to generate statistics related to the marketing channels and advertising partners through which users learned about and signed up for FlyVPN mobile apps.

Disabling or resetting mobile identifiers
Users may disable or reset the mobile identifiers associated with their devices at any time. For instructions, see Apple's page on Advertising & Privacy on iOS devices and Google's page on Managing your Google Settings on your Android device.

Personal data of underage persons

Persons younger than 18 shall not use the FlyVPN Services and provide any personal data to us without the supervision of the parents or guardians. Based on the above, it is presumed that any person using the FlyVPN Services and supplying personal data to us is at least 18 years of age. If a person younger than 18 years old or a person, supplying wrongful data, become known to FlyVPN, such person and all their data may be immediately and without any notice withdrawn by suspending their access to FlyVPN Services.

Users in the European Union

FlyVPN 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:

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.
  • 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.
  • With the consent of users, which users can withdraw at any time.

    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@flyvpn.com.

    Your personal data protection rights

    You may request us to inform you about the personal data that we have collected about you, to request any changes or correction of inaccurate information, to object to certain processing of personal data (e.g. for marketing purposes), to provide you with a copy of your personal data in a structured, commonly used and machine-readable format, to transmit (if technically feasible) your personal data to another controller, or to erase your personal data. You also may request to restrict the processing of your personal data (when there is a legal basis for that). In cases where your personal data is processed on a separate consent basis, you have the right at any time to withdraw your consent to the processing of your personal data.

    If you disagree with your data processing by FlyVPN, you are free not to use the FlyVPN Service, and to discontinue using it at any time. You may request us to discontinue processing of your personal data, in which case your data will be processed only as much as it is necessary to effect the discontinuation of your use of the FlyVPN Services (e.g., final settlement, or deleting all personal data based on your email address), or finalizing other FlyVPN's legal relationship with you (e.g. accounting, invoicing, processing refunds).

    If you wish to use the FlyVPN Services again, you will have to accept and agree to this Privacy Policy anew.

    Term for storing personal data

    FlyVPN user stores limited personal data for the whole period when the FlyVPN Services are used and for no longer than 2 years after last use of the App and/or the Services.

    Other Terms

    FlyVPN would like to remind you that you are yourself responsible for the security of your data. We ask you to be careful when using and storing personal data containing files on your devices, as well as the devices itself. Please ensure that nobody accesses and uses your devices without your consent.

    You shall be extra careful and not disclose your personal information to unrelated third parties, since such information may be used in different ways and against your interests, including activities such as fraud, invasion of privacy, identity theft, etc.

    In order to ensure security of the personal data, FlyVPN employs various administrative, technical and physical security measures, however it is your responsibility to exercise caution and reason when using the FlyVPN Services. You will be personally responsible if such action violates any third party's privacy or any other rights, or any applicable law. Under no circumstances, FlyVPN is liable for the consequences of your unlawful activities, your willful and negligent activities violating applicable laws or third party rights, as well as any circumstances, which may not have been reasonably controlled or foreseen.

    This Privacy Policy may be modified and updated at any time, at our sole discretion, for any or no reason, and without liability, as indicated below. The date of the most current wording of the Privacy Policy is indicated at the top of the text. We ask all users to ensure that they are familiar with the most current wording of the Privacy Policy. The amendment of the Privacy Policy may be communicated to you by sending an email and/or by publishing the updated Privacy Policy on the FlyVPN website. Please consider reviewing the Privacy Policy each time you use the FlyVPN Services. Updates of the Privacy Policy come into force as of the moment when they are published.

    You may not assign or transfer your rights or obligations under this Privacy Policy to any third party.

    How to Contact FlyVPN

    Please contact us by email at support@flyvpn.com if you have any questions on our Privacy Policy or you want to enforce any of your rights related to your privacy.

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