Privacy Policy

April, 8th, 2024

1. INTRODUCTION

This Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information in relation to our mobile services, web site, and any software provided on or in connection with TurbineVPN services (collectively, the "Service"), and your choices about the collection and use of your information.

By using our Service you understand and agree that we are providing a platform for you to post content, including photos, comments and other materials ("User Content"), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.

Our Policy applies to all visitors, users, and others who access the Service (“Users").

2. INFORMATION WE COLLECT

We collect the following types of information:

Information you provide us directly:

• The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

• When you register with us and use the Application, you generally provide (a) your name, email address, and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) information you enter into our system when using the Application, such as contact information and business management information.
• We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.
• User Content (e.g. photos, comments, and other materials) that you post to the Service.
• Communications between you and TurbineVPN. For example, we may send you Service - related emails (eg, account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service - related e-mails.

 

Analytics information:

• We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

Cookies and similar technologies:

• When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use TurbineVPN and provide features to you.
• We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

Log file information:

• Log file information is automatically reported by your browser each time you make a request to access (ie, visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
• When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
  
  

Device identifiers:

• When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by TurbineVPN.
• A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
  
  

Metadata:

• Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
• Users can add or may have Metadata added to their User Content including a hashtag (eg, to mark keywords when you post a photo), geotag (eg, to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other's APIs then, your latitude and longitude will be stored with the photo and searchable (eg, through a location or map feature) if your photo is made public by you in accordance with your privacy settings.
  
  

3. HOW WE USE YOUR INFORMATION
   In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:

• help you efficiently access your information after you sign in;
• remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
• provide personalised content and information to you and others, which could include online ads or other forms of marketing;
• provide, improve, test, and monitor the effectiveness of our Service;
• develop and test new products and features;
• monitor metrics such as total number of visitors, traffic, and demographic patterns;
• diagnose or fix technology problems;
• automatically update the xTurbineVPNlication on your device;
  TurbineVPN or other Users may run contests, special offers or other events or activities ("Events") on the Service. If you do not want to participate in an Event, do not use the particular Metadata (ie hashtag or geotag) associated with that Event.

 

4. SHARING OF YOUR INFORMATION

We will not rent or sell your information to third parties outside TurbineVPN (or the group of companies of which TurbineVPN is a part) without your consent, except as noted in this Policy.

Parties with whom we may share your information:

• We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that TurbineVPN is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates own services (including by providing you with better and more relevant experiences). But these Affiliates will honor the choices you make about who can see your photos.
• We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organisations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
• We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
• We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

 

Parties with whom you may choose to share your User Content:

• Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. To change your privacy settings on the Service, please change your profile setting. Once you have shared User Content or made it public, that User Content may be re-shared by others.

• Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users and subject to use under our TurbineVPN API.
• If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the TurbineVPN API have copied or saved that information.

What happens in the event of a change of control:

• If we sell or otherwise transfer part or the whole of TurbineVPN or our assets to another organization (eg, in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

Responding to legal requests and preventing harm:

• We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

5. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. However, some data may still be stored for a certain time period if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

6. EXERCISING YOUR RIGHTS

For the data we store and access you are entitled to address us regarding the following issues:

• Data Access and Portability. You can request copies of your personal information held by us.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask us to correct change, update or rectify your data.
• Data Retention and Deletion. We generally retain data for as long as your account is in existence or as needed to provide the App. However, specific retention times can vary based on context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account at any time. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.

Please bear in mind that we ensure the above mentioned rights only with respect to the information that you submit.

When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the “How to contact us” section of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

Please note that you can opt-out of marketing tracking by moving the "Limit Ad Tracking" in the settings on your mobile phone to “on”.

US regional patterns:

Residents of the State of California (USA) have the right to request a list of all third parties to whom our App disclosed certain personal information (in accordance with the laws of the State of California) in the previous year for the purposes of direct marketing of such third parties. If you are a resident of the State of California and want to receive such a list, please contact us through the email displayed below. When submitting such a request, please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California", as well as your name, address, city, state, and zip code. In the text of your request, please provide us with sufficient information so that we can determine if the above requirements of the law apply to your situation. You must confirm that you are a resident of the State of California (USA) and provide the current address in the state of California for our response. Please note that we do not accept calls by phone, mail or facsimile, nor are we responsible for calls that are flagged or misdelivered or that do not contain exhaustive information.

7. HOW WE STORE YOUR INFORMATION

Storage and Processing:

• Your information collected through the Service may be stored and processed in the United States or any other country in which TurbineVPN, its Affiliates or Service Providers maintain facilities.
• TurbineVPN, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from US law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
• By registering for and using the Service you consent to the transfer of information to the US or to any other country in which TurbineVPN, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
• We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, TurbineVPN cannot ensure the security of any information you transmit to TurbineVPN or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
• Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and TurbineVPN, at all times. Your privacy settings may also be affected by changes the social media services you connect to TurbineVPN make to their services. We are not responsible for the functionality, privacy, or security measures of any other organisation.

 

8. CHILDREN’S PRIVACY
   TurbineVPN does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.
9. OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.

10. HOW TO EXERCISE MY RIGHTS

If you wish to use any of the rights described below, you may contact us at any time by emailing us at support@turbinevpn.com.

Mandatory verification: We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods. To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, changed the device you used to access the App or you already requested us to delete your personal data.

11. CHANGES TO OUR PRIVACY POLICY

TurbineVPN may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of TurbineVPN or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

12. HOW TO CONTACT US

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@turbinevpn.com.