RoxiVPN Privacy Policy

Last Updated: 13 JUNE, 2019


1. SCOPE OF THIS PRIVACY POLICY

This privacy policy statement (“Privacy Policy”) describes how Roxi Security, s.r.o. and our affiliates (“RoxiVPN,” “we,” “us,” or “our”) obtain, use, store, change, disclose, and delete our users’ (“you,” or “your”) personal data as it relates to RoxiVPN’s products, services, websites, mobile and desktop applications, and marketing practices. This Privacy Policy is a part of and is incorporated into the Roxi Security, s.r.o. End User Agreement between RoxiVPN and you. We ask that you read this Privacy Policy carefully as it contains important information on how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us in the event you have a privacy concern or complaint.

For the purposes of this Privacy Policy, the term “personal data” means any information relating to an identified or identifiable natural person. The term “personal data” does not include any information that has been anonymized, such that the natural person to which such information relates is not identifiable.

For the purposes of this Privacy Policy, the term “VPN Services” means all of RoxiVPN’s Virtual Private Network (VPN) Services. RoxiVPN does not monitor, store, or log your online activity, including your browsing history, connection times, metadata, downloads, server usage, or data content during your session in the VPN Services. For a list of categories of personal data that RoxiVPN collects, see Section 2 of this Privacy Policy.

RoxiVPN also never stores or logs your IP address after the end of your session in the VPN Services – RoxiVPN always removes your IP address after your session ends. See Section 7 of this Privacy Policy.

If you have any privacy or personal data concern related to any of RoxiVPN’s products, services, or practices, please contact us at support@roxivpn.com.

Please review our other relevant policies and agreements:

END USER AGREEMENT

2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

IMPORTANT:YOUR FAILURE TO PROVIDE CERTAIN PERSONAL DATA MAY MAKE OUR WEBSITES AND APPLICATIONS OPERATE NOT AS INTENDED OR NOT OPERATE AT ALL FOR YOU. YOUR FAILURE TO PROVIDE CERTAIN PERSONAL DATA MAY ALSO MAKE IT IMPOSSIBLE FOR US TO PROVIDE SOME OF OUR PRODUCTS AND SERVICES TO YOU, BECAUSE OUR PRODUCTS AND SERVICES REQUIRE CERTAIN MINIMUM PERSONAL DATA IN ORDER TO OPERATE AS WE INTEND.

PERSONAL DATA THAT YOU PROVIDE

Upon your registration for and use of RoxiVPN’s products and services, we collect certain personal data directly from you, in each case only if applicable, including the following:

PERSONAL DATA THAT WE COLLECT AUTOMATICALLY

Upon your use of a RoxiVPN’s website and activation and/or use of a RoxiVPN app, we collect certain personal data from you, in each case only if applicable, including the following:

PERSONAL DATA THAT WE COLLECT FROM OTHER SOURCES

We may also collect personal data, such as names and contact information, from third parties, such as marketing, research, sales lead generator companies, social networks, as well as from any publicly-accessible sources. We also collect your payment history regarding our products and services (but not your payment information) from third-party payment processors, such as Google, Apple, PayPal, Amazon, Alipay and Cardinity.

3. HOW WE USE PERSONAL DATA

We use your personal data on the following legal bases, and for the following purposes:

Based on your consent, including:

For the performance of a contract, or in order to take steps prior to entering into a contract, including:

For compliance with our legal obligations, including:

For the purposes of our legitimate interests, or the legitimate interests of our other users and other third parties, including:

4. WHEN AND WHY WE SHARE PERSONAL DATA

A. RoxiVPN will never sell or rent your personal data to any third parties. We do, however, need to share your personal data to run our everyday business. We share your personal data with our affiliates and third-party service providers for everyday business purposes, including to:

B. We may share your personal data when appropriate or necessary to respond to legal process, including lawful:

C. We may share your personal data if we are, or propose to be, acquired by or merge with another entity or entities, or if we sell, or propose to sell, all or substantially all of our assets to another entity or entities, in which case we would share your personal data with such entity or entities.

5. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You can limit your sharing and our use of your personal data when it is based on your consent. For example, you can control our use of cookies by using the settings of your internet browser. Please be aware that your limit on our use of personal data may cause our websites and applications to appear and function not as intended. You can also limit our use of your personal data for our marketing purposes. Click here to set your marketing preferences.

If the laws of some countries apply to you, you may have the right to do the following:

RIGHT TO OBJECT

If the laws of some countries apply to you, you may have the “right to object” to our processing of your personal data when such processing is based on our, or a third party’s, legitimate interests. We will stop processing your personal data, unless:

If you object, we will stop processing your personal data for direct marketing purposes.

In order to request to exercise any of your rights, we may require you to provide us with detailed information about your request. Your rights are also subject to certain other limitations contained in the applicable law.

6. WHERE AND HOW WE STORE AND TRANSFER PERSONAL DATA

We use appropriate physical, electronic, technical, and organizational measures to secure and protect your personal data to ensure a level of security appropriate to the risk. You should understand, however, that no safeguards are guaranteed to prevent unauthorized disclosure and/or use of personal data. Because of that, we cannot guarantee or warrant that your personal data will never be exposed. We use third-party service providers globally to store and transfer personal data. We work with our third-party service providers to put in place adequate protections to ensure the security of personal data when it is stored and transferred.

7. HOW LONG WE STORE PERSONAL DATA

We do not store certain personal data (i.e. Section 2(B)(i-ii, iv-v)) that we collect automatically. We store some of your personal data that we collect from you and from other sources as long as you remain a user of our products and services. We retain personal data necessary for compliance with our legal obligations and contractual performance for the longer of: (i) the required time period under applicable law; (ii) or seven years.

8. COPPA

The Children’s Online Privacy Protection Act (“COPPA”) is a United States federal law enacted to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13. Our products and services are not directed to children under the age of 13, nor do we knowingly collect information from children under the age of 13. If you are under the age of 13, please do not provide personal information of any kind whatsoever to RoxiVPN. If a child provides us with personal information, a parent or legal guardian of that child may contact us to obtain that information and/or delete it from our records by sending an email to privacy@roxivpn.com.

9. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy (and/or other applicable policies and Addenda) as the applicable laws, relevant technologies, and our data processing practices change. We will notify you of changes to this Privacy Policy (and/or other applicable policies and Addenda) by posting the updated policy on our website and in our applications and other products and services. The changes to this Privacy Policy (and/or other applicable policies and Addenda) shall become effective upon such posting (as indicated by the date following “Last Updated:” at the top of this Privacy Policy and/or other applicable policies and Addenda), or as otherwise required by applicable law. We encourage you to review this Privacy Policy (and other applicable policies and Addenda) on a periodic basis.