PRIVACY POLICY

[Last Modified: November 2022]

First and foremost, before we dive into the legal details of our privacy policy we wish to make it clear – We do not want to know your identity or any other personal information about you and we do not collect data to try and figure out who you are. We don’t require registration of any kind in order to use our services. Of course, we do provide all of the regular privacy policy information to which you are entitled, and we will get to that in a minute. But in case you do not have the time or patience to read through the whole policy, we want to repeat and make that point perfectly clear: We do not want to know your identity, preferences or any information about you personally.

This Privacy Policy (“Privacy Policy“) governs the manner in which we process information collected from our users (“you“, “your” or “user“) in connection with their access to or use of our (i) 1ClickVPN mobile application available on iOS (“Mobile App“) and (ii) 1Click VPN Desktop EXE software for Mac (“Desktop App” and together with the Mobile App the “Product”) all as detailed and defined in our Terms of Use (“Terms“).

All capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy explains what information we may collect, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR“) and the California Consumer Privacy Act (“CCPA”).

In the event you are a California resident, and the CCPA applies to you – please review our CCPA Privacy Notice below.

 

POLICY AMENDMENTS:

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective upon publication of the amended terms in this Privacy Policy. Your continued use of the Services, following the amendment of the Privacy Policy, constitutes your acknowledgement and consent of such amendments to the Privacy Policy. The last revision will be reflected in the “Last Updated” heading above. In the event of a material change we will make a reasonable effort to provide a notification of such change. We recommend that you periodically review this Privacy Policy, as it may be subject to amendments from time to time.

 

CONTACT INFORMATION AND DATA PROCESSOR INFORMATION:

You may contact us and our privacy team as follow by sending us email to: privacy@1Clickvpn.com

 

DATA SETS WE COLLECT AND FOR WHAT PURPOSE: 

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.

 

Non-Personal Data

During your interaction with our Platform and Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.

 

Personal Data

We may also collect from you, during your access or interaction with the Platform or Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

 

The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:

DATA SET	PURPOSE AND OPERATION	LAWFUL BASIS
Contact Information: If you voluntarily contact us following your interest in our Services, support or other inquiries, through any form available on the website or by email, you may be required to provide us with certain information such as your full name, email address, and any additional information you decide to share with us.	We will use this data to provide you with the support you requested or to respond to your inquiry. We may also process the contents of our correspondence with you in order to improve our customer service.	We will process this information subject to our legitimate interest.
Usage Data: When you access the Product or Services we may, either directly or indirectly (through our third-party service providers or tools) collect certain behavior data to better understand how you use the Product and Services, including click stream, features used, duration, crash and error data, etc. (“Usage Data”). The Usage Data may include Personal Data.	We will use this data in order to operate, provide, maintain, protect and manage our Services.	We process such information subject to our legitimate interest.
We may collect certain Online Identifiers such as, machine ID and your IP address (“Online Identifiers“).	We will use your Online Identifiers to provide the Services as well as to extract the approximate geographical location (i.e., country). In addition, we will collect, use and share this data to provide the Residential IP Service to other users in the community, in the same way that you receive them.	Your Consent.

 

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the Product, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.

 

HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

• Automatically, when you interact with our product, including through the use of tracking technologies.
• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.

 

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your data with third parties, including our service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT	DATA THAT WILL BE SHARED	PURPOSE OF SHARING
Residential Proxy Community Members	Online Identifiers	Our Services include using and sharing our users Residential IP with other users in the community, in the same way that you receive other users IP in order to be provided with our Residential IP Services. Our Services which are based on the ability to share your IP address with other users in our community and to allow other members of our community to use your device resources in order to browse online
Trusted Agents and Service Providers	All data	We may disclose Personal Data to our trusted agents (such as legal counsel) and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, etc.) so that they can perform the requested services on our behalf. These providers are prohibited from using your Personal Data for any purposes other than providing us with requested services. When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
Any acquirer of our business	All data	We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
Legal and law enforcement	Subject to law enforcement authority request.	We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

 

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

USER RIGHTS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination and the right to cease sharing or selling your information as such term is defined under the CCPA.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to: privacy@1Clickvpn.com

Further, certain rights are available within the Mobile App: you may correct, revise and delete information from the Mobile App settings at any time, any consent provided may be easily withdraw, therefore we recommend you use the technical solutions we have provided you with to exercise your rights.

 

DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

 

SECURITY MEASURES:

While there are inherent risks involved in all data transmissions over the Internet or wireless networks, and other security risks that apply to stored data, and we therefore cannot guarantee the security of your information, we use our best efforts, using industry-standard encryption and security technologies and methods, to collect and store information collected from you in a secure and safe manner.

INTERNATIONAL DATA TRANSFER:

We may process or store Personal Data within the EEA, US, and internationally. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the Standard Contractual Clauses approved by the European Union.

 

ELIGIBILITY AND CHILDREN PRIVACY:

The Services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at privacy@1Clickvpn.com if you have reason to believe that a child has shared any information with us.

 

 

CCPA PRIVACY NOTICE

 

• INTRODUCTION

This CCPA Privacy Notice governs the manner in which we process information collected from users who reside in the State of California (“Consumers” as defined under the CCPA and will be referred to herein as “you”). Any terms defined in the CCPA have the same meaning when used in this Notice. Furthermore, this Notice is an integral part of our Privacy Policy, and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

• CATEGORIES of PERSONAL information

When you access our website and use our Service, we collect certain data regarding such use. This data includes “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device as detailed in the table below.

Please see below a table detailing the categories of Personal Information that we collect (and have collected within the last 12 months) as a “Business”:

Category	Examples of Personal Information	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	No
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

 

• DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers;
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

We disclose your Personal Information for a business purpose to the following categories of third parties: service providers and trusted agents.

When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

 

• SALE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we as a “Business” have not sold Personal Information.

We offer all consumers the same ability to opt-out of the sale of their Personal Information that is available to California residents under the CCPA. Based on the CCPA’s broad definition of “sale” certain data collected on our website may be considered a “sale” under the CCPA. You may opt out by by using our DSR Form.

As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this Privacy Policy.