N.B. We understand your legitimate privacy concerns. We want You to know We are committed to safeguarding Your privacy and Your security whenever You navigate through the Internet.
We believe in privacy and online freedom and that it should be very clear how we manage and protect your personal information. If you have any questions or concerns, please contact us.
Since We only collect the minimal usage statistics needed to maintain the quality of our service, and do not store Your personal information, We cannot, willingly or unwillingly, share Your information with third-parties or government authorities - because this data does not exist.
to protect any confidential information from an unauthorized access, illegal use or loss; to protect individual’s rights and freedoms while using the confidential information at the VS Softwareline LTD resources; to protect individual’s rights for privacy, personal and family secret. The policy is elaborated in compliance with international acts based on the “Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data” of the Council of Europe dated 28th January 1981 and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (The General Data Protection Regulation – GDPR).
I. General Definitions 1. Under the present Policy we deem confidential any information we obtained, that has not been officially disclosed, published and/or revealed, is not publicly available or commonly known, as well as legally or illegally circulated by any third party, and that may represent economical, financial, commercial, legal or any other value by virtue of its being unknown to a third party.
2. VS Softwareline LTD acting as data controller also deems confidential individual’s Personal Data, provided to us.
'Personal Data' – any information directly or indirectly is related to a natural person. The following information is regarded as “Personal Data”: the first and last names, date of birth, e-mail address, phone number or any other contact information, your photo or video image, payment card data, transaction data, bank statements, payment account data if any, as well as any other information, directly or indirectly related to a natural person.
The personal information we may collect may include, but is not limited to, the following:
E-mail address, and any other personal or preference information that you elect to provide to us. We only use Your email address to alert You to payment transactions, password changes, updates and announcements. Minimal usage statistics to maintain our quality of Service: date and time on which You start and on which end use our Services, the amount of data transmitted during each session of use of the Services, to which location (eg. UK) (We do not hold servers’ IP addresses), and from which country You connected from (We do not hold IP addresses). We guarantee that We will never log Your browsing activity, data or IP addresses including: Any of the websites you visited in the past or plan on visiting in the future, any data You may have downloaded, shared, or viewed, any of your IP address or DNS queries. Information created by Your when using of the Website (the date and time of visits to the Website, the pages viewed, time spent on the Website, and the Internet sites visited just before and just after the Website). If you email or otherwise contact Us, we may keep your message, email address and contact information to respond to your request. Your provision of such information is entirely optional.
'Processing of Confidential information and Personal Data' – any action (operation) or a chain of action (operation), involving the use Confidential information and Personal data, including use by means of electronic facilities, inter alia gathering, recording, systematization, accumulation, storage, specification (updating, modifying), extraction, usage, sharing (circulation, provision, access), depersonalization, blocking, deletion, elimination of Personal data.
'Consent' – a statement of a natural person or their representative, containing consent for the processing of their Confidential information and Personal data, including by means of electronic facilities.
II. Principles of Confidential information and Personal Data Processing 1. VS Softwareline LTD performs the processing of Confidential information and Personal Data on a lawful and fair basis in accordance with the following principles:
legitimacy of the purposes and ways of Confidential information and Personal Data processing and bona fides; accordance of the purposes of Confidential information and Personal Data processing with the purposes, previously defined and stated for Confidential information and Personal Data gathering; accordance of the volume and type of the processed Confidential information and Personal Data, methods of processing with the purposes of Confidential information and Personal Data processing; accuracy of Confidential information and Personal Data, its sufficiency for the purposes of processing, inadmissibility of the processing of Confidential information and Personal Data, excessive towards the aims, stated for Personal data gathering; inadmissibility of consolidation of Confidential information and Personal Data databases, created for incompatible purposes; minimization of collecting information. III. Purposes of Gathering, Processing and Use of Confidential information and Personal Data 1. The main purposes of gathering, processing and use of Confidential information and Personal Data are as follows:
2. We automatically process the information you provide, when you use Our website, Mobile application or when you contact us or our partners via e-mail, by phone or any other means of communication in order to identify Your needs, raise the quality of Our services, timely execute financial transactions, inform Your, as well as for other purposes, related to the functioning of the Website and Mobile application as it stipulated here before.
3. We store Confidential information and Cookies on the different servers so it is totally impossible to cross-reference Confidential information and Cookies in the case of illegal access to one of Our servers.
4. We obtain Personal data only from You or Our partners and providing that our partners got Your personal consent for the processing of Your Personal Data.
5. By securing consent of a natural person, VS Softwareline LTD reserves the right to obtain Personal data from a third party. In case of absence of such consent, VS Softwareline LTD may notify the natural person about the necessity of obtaining this information stating purposes, expected sources and ways of obtaining Personal data, as well as the nature of data and the consequences of a refusal to grant consent for obtaining such data.
6. In the event of changes in a Personal Data he/she may notify VS Softwareline LTD about these changes and provide appropriate documents.
7. VS Softwareline LTD has the right to gather, store, circulate and use Personal Data, as well as the information about the private life of the individual, provided that this information has already been released to public or disclosed by the individual himself or at his/her own will.
V. Use of Confidential Information 1. We use your personal information to:
Provide you with personalized Services and a personalized experience on our Website, Mobile application; Provide you with timely and reliable services; Research, develop, manage, protect and improve those Services and the Website; Develop and maintain our relationship with you and communicate with you. 2. While processing any Confidential information VS Softwareline LTD ensures accuracy of the Personal Data, its sufficiency, and whenever necessary its relevance towards the purposes of Personal data processing. VS Softwareline LTD undertakes all necessary measures, or secures their taking to delete or specify incomplete or inaccurate data.
3. To achieve the purposes stipulated by the present policy, VS Softwareline LTD reserves the right to share your Personal data with our trusted partners upon your consent only.
4. As we provide a transit service and some fragments of data (no more than 4 kB per type of packets per user session (ICMP, TCP, UDP)) can settle from time to time. Nevertheless, our service is never engaged in decoding and / or recovery of user data in any form and does not conduct analytical or other evaluation of user connections. All data received from an encrypted VPN connection between the user's device and our service is always sent to the destination server without changes (additions, deletions, modifications). Sources and addressees of connections are not logged and the fact of installing a connection cannot be tracked after its completion / discontinuity even with full access to the system.
5. We may use information derived from the aggregation of user data with other data for research and analytics purposes and improvement and marketing (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the user.
6. With regards to registration information if any, we use such information to authenticate login to the Services, to communicate with user. Additionally, we may use personal data to inform user of any updates to the Services, including new features and functionalities.
VI. Disclosure of Confidential Information 1. Confidential information may be disclosed in compliance with the requirements of the applicable law, as well as in the following cases:
upon a court’s request or any other similar inquiries; for protection of Your rights and/or property; for Your personal security. VIII. Confidential Information Storage 1. VS Softwareline LTD stores Confidential information in a form that allows to identify a natural person, as long as it is required for the purposes of Confidential information processing (usually not longer than 30 calendar days). The processed Confidential information are subject to deletion or depersonalization upon accomplishing of the purposes or in case accomplishing of the purposes is no longer required.
IX. Consent You are under no obligation to provide us with Personal Information, but Your refusal to do so may prevent You from using the Website and Mobile application.
2. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact us using the contact information provided in the 'Contact Us' section. We will inform you of the implications of withdrawing consent.
3. We will not, as a condition of the supply of services, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
4. Since VS Softwareline LTD operates in different countries, by using the Website and Mobile application, you guarantee that you have necessary consent of natural person for cross-border sharing, including jurisdictions with underdeveloped Confidential information protection legislation. However, VS Softwareline LTD endeavors to provide high standards of Confidential information protection by our partners regardless of their location.
X. Confidential information Protection 1.To ensure Confidential information protection we take the following steps:
collection of minimal required data; security equipment; hardware facilities and software packages for data protection; the list of the personnel, whose responsibilities require access to the Confidential information, is strictly restricted and regulated; other step stipulated by law. XI. Third Party Websites 1. VS Softwareline LTD cannot guarantee the protection of the confidential information you provide at third party websites, to which the website links or on the websites, which refer to our website, because these sites are operated independently from us. The use of information gathered on these websites is regulated by their own Privacy Policies. We bear no responsibility for the actions of such third parties and use of confidential information they gather.
XII. Cookies 1. When you visit the Website, we place a text file called a 'cookie' in the browser directory of your computer's hard drive. A cookie is a small text document, which often includes an anonymous unique identifier. When you visit an Internet site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Internet site can send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits an Internet site to access the cookies it has already sent to you, not the cookies sent to you by other sites. The cookie cannot be read by any website other than the one that set up the cookies. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.
2. As you use our Site, the Site uses its cookies to differentiate you from other Users. Cookies, in conjunction with our Internet server's log files, allow us to calculate the aggregate number of people visiting our Site and which parts of the Site are most popular. This helps us gather feedback in order to constantly improve our Site and better serve our customers. Cookies do not allow us to gather any personal information about you and we do not generally store any personal information that you provided to us in your cookies.
XIII. Restrictions 1. At any time a natural person may restrict the usage of his/her Personal Data for advertising and promotional activities. If a natural person has any concerns regarding our use of Personal Data, such a natural person may contact us in accordance with the procedure specified by the Terms and Conditions.
XIV. Responsibility 1. VS Softwareline LTD strives to maintain the highest level of the applied technologies, implementing the cutting-edge IT solutions, however, it is obvious that we shall bear no responsibility for the violation of the confidentiality of the information that happened beyond our direct control and/or as a result of a third party’s fault. Therefore, we are not responsible for any losses arising under such circumstances.