Mogol Limited (hereinafter “we”, “us” or “our”) operates the website www.vpnhouse.net (hereinafter referred to as “Website”) and other applications such as the free and paid version of VPNhouse, including the mobile and desktop applications of VPNhouse (hereinafter “Services”) and is the controller of the information collected or provided via the Services and Website and Processor.
- on the Services and Website,
- in e-mail or other communications between you and the Services and Website,
- through the desktop and mobile applications of VPNhouse or applications that we recommended you download from the Website, Google Play, or Apple App Store, or
It does not apply to information collected by: us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Services or Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third- party websites and we are not responsible for their privacy statements, information or other practices.
2. Warrant Canary
As of December 01 2022, we have not received any National Security Letters or FISA court orders, and we have not been subject to any gag order(s) by a FISA court, or any other similar court(s) of any government. We have never placed any backdoors in our hardware or software and have not received any requests to do so. No searches or seizures of any kind have ever been performed on our assets.
3. Information We Collect and How is your Personal Information Collected.
We do not store any of your personal information other than your email address. (personal data, or personal information, means any information about an individual from which that person can be identified by) (“Personal Information”). You do not have to give us any other Personal Information to browse our Website or use our Services.
- Direct interactions.
- Automatic data collection technologies or interactions.
Personal Information provided by users through Direct Interactions
- Account Information. E-mail/username if you create a VPNHouse account.
- Contact data. Email address.
- Marketing and Communications Data. Your communication preferences and preferences in receiving marketing from us, our third parties affiliates or partners.
Personal Information automatically collected from users through Automatic Data Collection Technologies or Interactions
- When VPNHouse app is launched, but before you connect to the VPN,we and our third party service providers collect device-specific information such as unique mobile ID, operating system and platform, browser type and version, network information and other technology on the devices you use to access the Website or the Services.
- When you connect to the VPNhouse VPN,we collect your internet protocol (IP) address, which we pseudonymize, immediately encrypt it and store it only for the duration of your VPN session. Your IP address is deleted after you disconnect from the VPN without storing or logging it. We do not associate your IP address with your online activities and we do not store or log your IP address with your online activities.
- Usage Dataincludes non-personally identifiable aggregated information about how you use our Services and Website. We do not attribute any specific website visits or app usage to any specific user. We do not keep logs of your online activities and will never associate any domains, websites or applications that you use with you, your device or your email.
- Aggregated Data.We may also collect, use and share your data to produce and share aggregated data that do not identify you and therefore not considered as Personal Information. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Services feature, to generate statistics about our users or to calculate ad impressions clicked on.
- As you navigate through the Website, we and our third party service providers use automatic data collection technologies to collect certain information about your equipment, including information such as your device information (including device and application IDs), unique mobile ID, advertising ID, operating system and platform, browser type and version, internet service providers, mobile network names and cookie information. Such information is used only used to improve the Website, provide troubleshoot and perform analytics.
- Disabling Cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, be notified when you receive a new cookie, or to disable cookies. Website visitors who disable their browsers’ ability to accept cookies will be able to browse the Website but certain Website features will not function.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We will only use your Personal Information when applicable local law allows us to. We may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using it. Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or other communication method. We do not sell or rent Personal Information to others, we do not log your browsing data and we delete your IP address when you disconnect from VPNhouse’s VPN.
- To verify your identity when you login to the Services;
- To administer, maintain and improve our Services;
- Provision of services: to present our Services and their contents to you, including any interactive features on the Services, and to provide you with information, products or services that you request from us;
- Customization of content: to perform research and analysis about your use of, or interest in, our Services and Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other sites;
- Advertising: To communicate with you and send you promotional information that may interest you about products, services, and offers made available by us, our affiliates or our marketing partners if you have consented to receive such information from us;
- To analyze usage and trends on our Services and to better understand how users use the Services.
- Business purposes such as audits.
- Functionality and security: to diagnose or fix technology problems, and detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
- Compliance: to enforce our terms and conditions and to comply with legal and regulatory obligations;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Service Providers. With third party service providers who provide services on our behalf such as processing payments (Probiller, Google Play and Apple App Store). Our service providers receive only the information necessary to perform their designated functions, and are not permitted to use or disclose this information or your Personal Information for their own marketing or other purposes;
- Aggregate, Anonymous or De-Identified Information. Sharing aggregate or non- personally identifiable information with non-affiliated third parties for advertising, marketing or research purposes. We do not store or share your personal information with any third parties for their own marketing, advertising or research purposes.
6. Security Measures We Have In Place
We use appropriate security measures (including physical, electronic and procedural measures) that are consistent with industry standards to protect your Personal Information we collect and maintain about you from loss, theft, misuse or unauthorized access or disclosure or destruction such as encryption, access controls, passwords or technical or physical security measures and safeguards. All employees and service providers are up-to- date on our security and privacy practices. Access to user Personal Information is restricted to those who need to know such information to perform their job functions.
Despite our efforts, no data security methods guarantee 100% protection. We do not promise and cannot guarantee that your Personal Information can never be viewed and/or used by others. You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Services.
7. Disclosure of your Personal Information
- Members of corporate group. To members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) who operate services that help us with: customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
- Service providers. To our authorized service providers that perform services on our behalf such as payment processing who may have access to Personal Information necessary to perform their functions but are not permitted to share or use such information for other purposes.
We do not log or store your IP address after you disconnect from the VPN, and we do not keep logs of your online activities.
We may disclose aggregated information about our users, and information that does not identify any individual. We may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope our users will find of interest.
8. International Users And Transfers of Your Personal Information to Other Countries
By using the Services you consent to the transfer of information that we collect about you, including Personal Information, to any country, including the United States or countries in Europe
9. Retention of Personal Information
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. The retention period that is necessary for compliance and legal enforcement purposes varies and depends on the nature of our legal obligations and claims in the individual case.
10. Choices about How we Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the Personal Information you provide to us.
- You can choose not to provide us with certain Personal Information, but that may result in you being unable to use our Services or certain features of them because such information may be required in order to register as a member (email is required to create a VPNhouse account); purchase products or services; contact us (email is required when contacting customer support); or initiate other transactions on our Services.
- You may delete your account with us at any time. If you delete your account, your Personal Information and all account-related information will no longer be accessible by you and will not be saved. After deleting your account, if you choose to have an account with us in the future, you will have to sign up for a new account.
11. Your Rights Related to Your Personal Information
- to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
- to rectify inaccurate Personal Information concerning you (right to data rectification);
- to erase your Personal Information (right to erasure, “right to be forgotten”);
- to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability);
- to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
- in some cases, to restrict our use of your Personal Information (right to restriction of processing).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. In case of a withdrawal of your consent you may no longer able to use several functionalities of our Services. You may send us an e-mail at email@example.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g. e-mail address). It is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
12. Use of Services by Minors
The Services are not directed to individuals under the age of sixteen (16) and we request that they not provide Personal Information through the Services. If we find out that a child under 16 has provided Personal Information, we will take steps to delete such information.
13. Changes to this Policy
14. Enforcement; Cooperation
15. No Rights of Third Parties
16. No Error Free Performance
17. California Consumer Privacy Act Notice
- Opt-out of the sale of their personal information, should we sell their personal information;
- Be informed of certain information concerning our collection and use of their personal information;
- Request that we delete certain personal information we collected from them;
- Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
- Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
This Service and Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Service and Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information.
18. Users in the European Union
VPNHouse 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 Data. 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.
- Providing Subscribers with the Services they have requested.
- Managing subscriptions in connection with our Services.
- Providing customer support.
- Enhancing the quality, reliability, and effectiveness of our Services.
- Communicating with customers to provide information and seek feedback related to our Services.
With the consent of users, which users can withdraw at any time.
- You have a right to access personal data held about you.
- You have the right to request that we rectify any personal data we hold that is inaccurate or incomplete.
- You have the right to request the deletion of your personal data. Please note that such deletion may result in us no longer being able to provide you with our Services.
- You have the right to request restriction of or object to the processing of your personal data.
- You have the right to request and receive your personal data in a commonly used format (data portability).
- You have the right to withdraw your consent on which processing is based at any time.
- You have a right to complain to your local data protection supervisory authority. · You can exercise your rights above by contacting us at firstname.lastname@example.org.
You may have a third party submit a request on your behalf as an authorized agent. To confirm that the authorized agent is entitled to submit a request on your behalf, they must have written authorization signed by you, and you must provide us with a copy of the signed authorization. To ensure your privacy and security, we may take further steps to verify your identity.
We will address any requests in accordance with applicable laws and to the best of our ability in a timely manner
19. Contact Information