Very Private Network, Inc. Privacy Policy

Last Updated on May 10, 2019

IMPORTANT: BY USING THIS APPLICATION AND/OR OUR PRODUCTS AND SERVICES, INCLUDING THOSE OF OUR AFFILIATES AND SUBSIDIARIES (collectively “Very Private Network”), YOU SIGNIFY YOUR AGREEMENT TO OUR PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THIS APPLICATION OR OUR PRODUCTS AND SERVICES, INCLUDING OUR WEBSITE AND WEB APPLICATIONS. THIS PRIVACY POLICY IS PART OF OUR TERMS AND CONDITIONS WHICH CAN BE ACCESSED ON OUR WEBSITE AND ARE INCORPORATED HEREIN BY REFERENCE, and can be viewed at: https://very-private-network.com/

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1. Privacy Rights

Very Private Network, Inc. (“Very Private Network” or “Us” or “We” or “Our”) is committed to respecting the privacy rights of its customers, visitors, and users of its mobile applications and website, as well as its related services (hereafter “Products and Services”). We created this Privacy Policy to inform you and provide necessary disclosures regarding our collection, use and sharing of information when you use Our Products and Services. We collect, use and share some of your information, as described below, to provide Our Products and Services and to measure and improve them over time. If you have any questions about this Privacy Policy, please contact Us at: contact@very-private-network.com.

PLEASE SEE VERY PRIVATE NETWORK’S TERMS AND CONDITIONS TO WHICH YOU ARE BOUND IF YOU USE, SUBSCRIBE TO, OR PURCHASE VERY PRIVATE NETWORK’S PRODUCTS OR SERVICES: https://very-private-network.com/

2. Not Intended For Use By Children

Our Products and Services are not directed at children who are under thirteen (13) years of age and We do not knowingly collect personal or other information from children. If you are younger than thirteen (13) years of age (or if you are less than sixteen (16) years of age and located in the European Economic Area, United Kingdom, or Switzerland – see Section 11 below for additional details), you should not use Our Products and Services and if you are between the ages of thirteen and eighteen you must have parental consent and you should not provide any personal identifiable information while using Our Products and Services without said parental consent. If you become aware that your child has provided us with personal information without your consent, please contact Us at contact@very-private-network.com. 

3. Information, Collected, Used and Shared by Very Private Network, Inc.

To provide you with Our Products and Services, we must collect and process information about you (“Customer Information”). When using Our Products and Services, you consent to the collection, storage, processing, sharing, transfer, manipulation, and disclosure of this information as described in this Privacy Policy.

Regardless of what country you reside in or provide information to Us from, you authorize Very Private Network to use your information as described herein in the United States and all other countries where Very Private Network operates or is available.

Very Private Network retains your information in accordance with legitimate business purposes for processing the information. Hereafter the data is removed, archived for restricted legitimate interests, or anonymized. Non-identifying information may be kept without time and use limitations.

What do we collect?

• Information about how you access Our Products and Services, such as IP address, advertising identifier, device identifier, device make and model, device settings, operating system, type of connection, carrier information, and browser information.
• Information about your use of Our Products and Services, what you clicked on, what you viewed, and session duration.

What is this information used for?

• We use this information to provide you with, and to improve upon, the Products and Services.
• We may use this information to carry out actions as instructed by you via your use of the Products and Services, such as the association of a photograph to your account, or sharing your location with your contacts.
• We may contact you with information about Our Products and Services, or to contact you as otherwise necessary, including if there has been a data breach.
• We may notify you of any changes in Our Products and Services, Terms and Conditions, or Privacy Policy.
• We may use this information to measure, analyze, and improve upon Our marketing efforts.
• We may share this information with third parties, or this information may be collected directly by third parties through integration of their technologies into the Products and Services, each as described herein.
• We may share certain aggregated information with third parties, which cannot be used to identify you individually.
• We may share this information in order to respond to law enforcement requests or when legally required to do so.
• We may share this information to verify or enforce compliance with user agreements and applicable laws, to protect against fraud, to detect and prevent security or technical issues, to protect against misuse or unauthorized use of Our Products and Services, or to protect against imminent harm to the rights, property or safety of Very Private Network, its subscribers, or the public as required or permitted by law.
• SEE VERY PRIVATE NETWORK’S TERMS AND CONDITIONS TO WHICH YOU ARE BOUND IF YOU USE, SUBSCRIBE TO, OR PURCHASE VERY PRIVATE NETWORK’S PRODUCTS OR SERVICES.
• In the event of a sale, merger, liquidation, dissolution, reorganization, assignment, bankruptcy or any transfer of assets, IP rights, or any marketable right owned by Very Private Network, your information may be sold or transferred as part of that transaction.

4. Third Parties and Information-Sharing

Very Private Network does not disclose your Customer Information to third parties except in the limited circumstances herein. 

In order to provide you with the Products and Services, we may establish business relationships with third-party companies (hereafter “Very Private Network Commercial Partners” or “Commercial Partners”). We verify that Our Commercial Partners utilize privacy and security practices consistent with Ours.

We allow these Commercial Partners to collect and process data, as described herein, to serve advertisements, including interest-based advertisements. We may use Commercial Partners to provide analytical services, which are used to provide, improve upon, and track performance of the Products and Services. We may use Commercial Partners to provide hosting, data storage, and direct marketing services. We may lease, rent, sell or share this information with Our Commercial Partners to the extent legally possible.

Very Private Network may provide links and/or connections to third-party applications, websites or services from within Our Products and Services (hereafter, “Third Party Services). We may not have access to, or control over, information collected by these Third Party Services. Such Third Party Services will handle, store, retain and access such user information in accordance with the terms and conditions of their agreements with you, if any, as well as their own privacy policies. You acknowledge that Very Private Network shall have no liability for sharing of such information to such Third Party Services and Very Private Network disclaims any and all liability relating thereto as set forth in its Terms and Conditions, which are expressly incorporated herein.

5. Cookies and Web Beacons

When you visit our website or otherwise use our Products and Services, we may use cookies (a small text file placed on your device to identify your device and browser when you use our Products & Services) and we may log certain personal data such as IP address, device type, browser type, operating system, and other information. We may also use Web beacons (an electronic file placed on a website that monitors usage).  We use this data to operate Our Products and Services, understand how they are used, diagnose technical problems, and improve upon your experience using Our Products and Services.

Most Internet browsers automatically accept cookies, but you can instruct your browser to stop accepting cookies (disable cookies). If you do, some of Our Products and Services may not function properly or may be diminished. Promotions or advertisements viewed through Our Products and Services may contain cookies.

6. Modifying or Removal of Your Customer Information

If you have subscribed to or purchased Our Products and Services and you wish to remove or modify your information, you can contact Us using the contact information provided below, although you should be aware that (a) there will be a technical delay between your request and the effective removal of your Customer Information from Our database, (b) we may have to retain Customer Information for legal purposes as the case may be; and (c) certain of Our Products and Services require the use of your information and such data is retained by Us and used as described in this Privacy Policy. You can delete your account and uninstall the Very Private Network application from your device. If you need assistance please contact Us at contact@very-private-network.com.

7. Security of Customer Information

Very Private Network seeks to adopt commercially reasonable security measures consistent with the industry regarding the protection against the loss, misuse or alternation of non-public information that is under Our control. Unfortunately, no security system, or system of transmitting data over the Internet can be guaranteed to be 100% secure. As such, you provide all such information at your own risk.

8. Data Transfer

Very Private Network is operated from the United States.  Our Products and Services may be accessed from outside of the United States, in which case personal information about your usage of Our Products and Services may be transferred to and stored in the United States, by Us and our Commercial Partners.  This transfer is required for us to provide the Products and Services as described in this policy.  We work hard to protect your privacy.  We endeavor to only partner with companies utilizing the industry appropriate technologies and privacy standards.

9. Changes to Very Private Network’s Privacy Policy

Very Private Network reserves the right, at Our discretion, to change, update or modify this Privacy Policy at any time by posting such change, update or modification on the Very Private Network website.

Any such change, update or modification will be effective immediately upon notice, which Very Private Network may provide by any means, including, without limitation, posting on the Very Private Network website, notifications within Very Private Network applications, or electronic mail.

Your continued use of the Very Private Network website and/or any Very Private Network products and services following the posting of changes will mean you accept those changes. Use of information that We gather is subject to the Privacy Policy in effect at the time of use.

10. For users located in the EEA, UK, and Switzerland

This section only applies to users located in the European Economic Area, United Kingdom, and Switzerland.

You must be at least 16 years of age to use Our Products and Services.

We may process your personal data for the following purposes and lawful processing basis:

• Legal compliance

• We may process your personal data as we are required to do so for legal reasons.  
• In this case your personal data may be shared with law enforcement agencies or government agencies.
• The legal basis of this processing is based on Our compliance with a legal obligations imposed upon Us, the protection of vital interests of data subjects, the performance of a task carried out in the public interest, or other legitimate interests We may have.

• Provisioning of Our Products and Services

• We may process your personal data for other purposes, such as the provisioning of Our Products and Services.
• In this case your personal data may be shared with Our service providers such as telecommunication companies, service providers we use to run the platform such as data analytics companies, or professional advisors such as lawyers, accountants, and analysts.
• The legal basis for this processing is based on the requirements for us to fulfill the performance of Our contract with you and Our legitimate interests.  

We aim to minimize the retention of data beyond when it is required by Us.  Data is retained by Us only for the minimum amount of time required by our legitimate interests, for compliance with legal obligations imposed upon us, or for tasks carried out in the public interest.  

You may request that your data be erased from Our Products and Services.  We will process your request when the data is no longer necessary for our legitimate interests or for compliance with legal obligations or for tasks carried out in the public interest.

You can reach our Privacy Officer at contact@very-private-network.com.

11. For suppliers & other third parties located in the EEA, UK, and Switzerland

This section only applies to users located in the European Economic Area, United Kingdom, and Switzerland.

We may process your data for the purpose of performing the obligations of a contract we may have with you.  We process this data based on our legitimate and legal interests, and the consent you provided when entering into a contract with Us.

We aim to minimize the retention of data beyond when it is required by Us.  Data is retained by Us only for the minimum amount of time required by our legitimate interests, for compliance with legal obligations imposed upon us, or for tasks carried out in the public interest.  

You may request that your data be erased from Our Products and Services.  We will process your request when the data is no longer necessary for our legitimate interests or for compliance with legal obligations or for tasks carried out in the public interest.

You can reach our Privacy Officer at contact@very-private-network.com.

We can be contacted concerning this Privacy Policy by email at contact@very-private-network.com.