Privacy Policy

Effective 8/1/2022

Introduction

This Privacy Policy (“Policy”) describes how UltraVPN handles information that we collect about you on our website, ultravpn.com/it, or through similar channels like email (the “Site”), our mobile application (the “App”), and in connection with our VPN service (the “Services”). We distinguish our information handling practices for the Site, the App, and the Services throughout this Policy.

When you use a VPN connection, we do not store any information that identifies what you browse, view, or do online via that VPN connection. We only log only the information absolutely necessary to provide you with outstanding VPN service.

By visiting our Site or using the Services, you are agreeing to the terms of this Policy and the accompanying Terms of Use. Capitalized terms are defined in this Policy or in the Terms of Use. If you do not agree to this Policy, please do not access or use our Services.

1. Information We Collect and How We Use It

UltraVPN collects the following types of information:

1.1. Account Information

This information is collected when you register for the Services (whether on the Site or on the App) and includes: your name, email address, payment information, or the information you provide us when you submit a Customer Support Request through your account. Your payment card information is used only to process payments for the Services. We may use your other account information for the following reasons:

  • To administer your UltraVPN subscription
  • To provide you with requested technical and customer service support
  • To send emails related to payment transactions
  • To provide links to our Site, including password reset emails
  • To send you updates and announcements
  • To communicate with you about your VPN services or respond to your communications
  • To send you marketing information about our products and other third-party products and services that we think may be relevant to you, such as offers, surveys, invitations, and promotions

1.2. Services Usage Information

UltraVPN collects the following limited information about how you use the Services when you are logged in:

1.2.1. Apps summary statistics

We collect information related to which Apps (e.g. UltraVPN iOS) and Apps version(s) users have activated. We also collect information related to which Apps (e.g. UltraVPN iOS) and Apps version(s) you have activated if you contact our customer support and provide us with this information.

1.2.2. VPN connection summary statistics

We collect information about whether you have successfully established a VPN connection, to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address). This minimal information assists us in providing technical support, such as identifying connection problems, providing country-specific advice about how to best use our Service, and to enable UltraVPN engineers to identify and fix network issues.

1.2.3. Anonymous App diagnostics

App diagnostic data, which include crash reports, usability diagnostics, and VPN connection diagnostics, are anonymized and cannot be tied back to you.

We use these data points in our network operations tools to help optimize network speeds and to identify problems and areas for improvement related to specific apps, VPN servers, or ISPs. We collect the following anonymized information:

  • Information about if the connection attempt was successful or not, and if not, what the reason was for the connection failure.
  • We might ask you to rate your connection and provide some more detailed information if you are not satisfied with the service. This information is not tied to a specific user.

1.2.4. Device hashes

A device hash is a random ID generated when you first launch UltraVPN. We use device hashes to identify your device in relation to any of the data points described in the points above. Device hashes are not linked to VPN browsing activity or user identity. We use devices hashes because we do not require users to register an account to use some of our products and need a way to distinguish between different users and carry out the activities above.

1.3 Information from Email and Feedback Forms

UltraVPN keeps records of any correspondence, questions, complaints, or compliments you submit to us through our Site or Services, along with our response. Depending on how you contact us, we may collect your email address and any additional information you provide to us. We use this information to provide you with customer service and for internal training and service improvement.

1.4 Information Automatically Collected When You Browse Our App

When you browse our App as a visitor, we automatically collect certain information about your device and activity on our App. The information below pertains only to information we collect from App visitors generally and is separate from information we collect in connection with the Services.

  • App identifiers. An App identifier is an identifier provided by an Android or iOS device. Consistent with your privacy settings on your mobile device, UltraVPN uses mobile identifiers to generate statistics related to the marketing channels and advertising partners that led to you learning about and signing up for UltraVPN mobile Apps.

1.5 Information Automatically Collected When You Browse Our Site

When you browse our Site as a visitor, we automatically collect certain information about your device and activity on our Site. The information below pertains only to information we collect from Site visitors generally and is separate from information we collect in connection with the Services.

  • Log files. As you use our Site, we automatically record information in log files. These log files may include information about the length and time of your visit, IP address, browser type and device type and settings, and other similar information.
  • Information from cookies and similar technology. A cookie is a small text file that is placed on your computer when you visit a website. Cookies and similar technologies enable us and our service providers to make sure our Site runs smoothly, allow us to improve our Site, and to identify when customers were referred to our Site by a service provider. More information about how we use cookies is in the section titled “Cookies”.

2. How We Share Your Information

UltraVPN does not store information about your browsing activity when you use the Services. We do not share your personal information with third parties except as described in this Privacy Policy:

  • Service providers. We use third-party service providers to help us with various operations with the App and our Website, such as payment processing, email automation, website and app diagnostics, analytics and other uses. Some of these providers may process your personal information. To protect your information, we require third parties to sign confidentiality and data processing agreements, review their security practices, and share only the information about you that is needed by them to perform their services. These service providers and their scope of services are:
    • Live chat and support service platform – Zendesk (provided by Zendesk Inc.) when you contact us for Customer Support;
    • Emailing service providers – Sendgrid (by Twilio Inc.);
    • Kochava SDK (by Kochava, Inc.) and VWO (by Wingify Software) for app diagnostics;
    • Hasoffers (provided by Tune Inc.) when you visit our Website;
    • Your personal information may be processed in any country in which we engage service providers. When you use our Services, you acknowledge the transfer of your personal information outside of the country where you reside.
  • Affiliates. We may share Account Information with our affiliated Aura Group companies.
  • In connection with a business transaction. If ownership or control of all or part of our services, assets, or business changes or an investment entity conducting due diligence in connection with an acquisition or investment, we may transfer certain information to the new owner.
  • Lawful Requests for Data. We carefully review each request for your data to make sure it is compliant with the applicable law. UltraVPN protects your information by not keeping logs of your online activity on our App (no IP addresses, browsing data, traffic information, etc.). This means that we are unable to link an individual App user to a specific IP address, connection timestamp or other information that we do not collect. Therefore, even when we receive a proper request, it might be impossible for us to identify you or provide any identifying information related to you. If we are able to identify you, we will provide the limited data we process.

3. Security Measures to Protect Your Information

UltraVPN uses physical, procedural, and technical security controls to help prevent any unintended disclosure of your information. Access to your Account Information and Services Information is restricted to our employees who require such access to perform their job functions. While our controls are strong, no data security measures can guarantee 100% protection.

4. Users in the European Economic Area and UK

4.1. Legal Basis for Processing

UltraVPN is committed to user privacy globally, minimizing collection of data and ensuring users have control over their personal information. 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 European Economic Area (“EEA”). The United Kingdom (UK) has a law similar to the GDPR.

We collect and process the data outlined in this Policy on one of the following legal bases:

  • For fulfilling our contractual obligations to users, including:
    • Providing users with the Services and Apps they have requested.
    • Managing user subscriptions and processing payments.
    • Providing customer support.
  • For a legitimate interest associated with the operation of our business, including:
    • Enhancing the quality, reliability, and effectiveness of our Site, Services, and Apps.
    • Communicating with customers to provide information and seek feedback related to our Services and Apps.
  • With the consent of users, which users can withdraw at any time.

4.2. International Transfers of Data

UltraVPN is based in the United States, and may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and transferees include other Aura Group companies and service providers. Laws in other countries may be different to those that apply where you reside. For example, personal data collected within Switzerland, the UK, or the EEA may be transferred and processed outside those jurisdictions for purposes described in this Policy. We have safeguards in place that help ensure that your data has the adequate level of protection. Please contact us if you would like more information about these safeguards.

4.3. Your Rights

The GDPR gives users residing in the EU the rights to access, correct, delete, or object to the processing of your personal information. If you are a resident of any EU member country, you may exercise these rights by contacting our Data Protection Officer (DPO). UltraVPN has appointed Bird & Bird DPO Services SRL as a DPO, and may be reached:

  • by using the following email: [email protected]/DPO email address of your choice
  • by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium

5. Cookies

We uses cookies on our Site to help us collect information about how you use the Site. We do not use cookies and similar technologies to track you when you are connected to the UltraVPN service.

We use first-party and third-party cookies for several reasons. Some cookies are necessary for technical reasons for our Site to operate and/or provide basic functionality to you, improving your experience on our Site, and related purposes.

The types of first- and third-party cookies we use on the Site are:

  • Strictly necessary cookies: These cookies are strictly necessary to provide you with services available through our Site and cannot be turned off.
  • Functional cookies: These cookies allow you to browse our Site or benefit from some of its enhanced features, such as using instant messaging support. If these cookies are disabled, it could impact your experience to use some Site functionality.
  • Analytics cookies: These cookies allow us or our third-party analytics providers to collect information and statistics on the use of the Site by you and other visitors.

5.1. Cookie Preferences

You can exercise your preference to receive or deactivate all types of cookies by managing cookies from your web browser. You must set your preference in each browser/device that you use and each time you use a new browser.

The following links provide more information on how to modify the cookies settings on some popular browsers: Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, Your Online Choices, or the Google Ads Settings page. If you choose to deactivate cookies, you may continue to use our Site but some useful features may not work anymore, depending on which cookies you deactivate.

6. Data Retention

UltraVPN does not retain data about your browsing activity while you are connected to the Services. For other information described in this privacy policy, UltraVPN generally retains this information for as long as is needed for the purpose it was collected. For instance, we will retain your account information as long as you are purchasing a subscription from us.

7. Children’s Information

The Site, App and Services are not intended for and may not be used by minors (i.e. under the age of 18 or as defined by applicable law) without appropriate consent or authorization from their parent or legal guardian. UltraVPN does not knowingly collect personal information from minors or allow them to use the Services. If you believe your child has provided information to us, please let us know immediately by emailing [email protected].

8. Your Rights and Choices

8.1. Unsubscribe to Marketing

To unsubscribe from our marketing communications, please click the “unsubscribe” link located in the footer of any marketing communications you receive from us.

8.2. Deletion of Account Information

You can request that we delete your Account Information from our servers by emailing [email protected]. Please note that we can only delete Account Information for users who have active UltraVPN subscriptions.

9. State Privacy Law Disclosures

Certain U.S. state laws require that we provide the following additional details regarding our privacy practices and your rights under these laws with respect to your “personal information”.

9.1. Information We Collect, Sources, and Uses

9.1.1. Sources of Personal Information

All the categories of personal information we collect come from the following categories of sources:

  • You (either directly or through your use of the Site, App or Services)
  • Our affiliates within the Pango family of companies
  • Third parties (such as service providers)

9.1.2. Categories of Information We Collect

We collect the following categories of personal information:

  • Identifiers (such as the information you provide when you register for an account)
  • Commercial information (such as your subscription purchase history)
  • Financial and transactional data (such as the payment card information you provide our payment processor when you purchase a subscription)
  • Internet or other network or device activity (such as Services Usage Information, explained above)
  • Customer service information (e.g. support requests)
  • Other information that identifies or can be reasonably associated with you

9.1.3. How We Use and Disclose Information

These categories of personal information are used and shared as described in Sections 1 and 2 of this Policy.

9.2. Your Privacy Rights

9.2.1. Access and Deletion

Certain state laws may permit you, if you reside in one of these states, to request that we:

  • provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, the business or commercial purpose for collecting or selling your personal information, and the categories of third parties with whom we shared personal information.
  • provide access to, or a copy, of certain information we have about you;
  • delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against for exercising certain of your rights.

To exercise any of these rights, please email us at [email protected].

When you exercise these rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). If you ask us to delete certain information, you may no longer be able to access or use the Services.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. If you do so, you must give the authorized agent written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

9.2.2. Opt-Out Rights

Under some state laws, you may have the right to opt out of the “sale” of your personal information or uses of information for targeted advertising purposes. Some of these laws broadly define “sale” and similar terms such that it may include allowing third parties to receive certain information, such as cookies, to deliver personalized advertising on our services, or intra-company sharing.

UltraVPN does not associate information about your browsing activity on the Services with other information that can be used to identify you, and does not sell such information either. However, UltraVPN may share personal information you provide when you register for an account with other Aura Group companies for advertising and marketing purposes. We may also allow third parties to use Tracking Technologies on our Site and App, as explained in Section 5 above.

The categories of information we may “sell” are:

  • Identifiers (such as advertising identifiers, cookies, and registration information)

To opt out of our use of your information for such purposes, visit: Do Not Sell My Personal Information . We do not knowingly sell the personal information of minors under 16 years of age without legally required authorization.

9.3. Do Not Track Signals

Some mobile and web browsers transmit ” do-not-track” signals. We action action in response to these signals.

9.4. Shine the Light Disclosure

California residents may request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” in the prior calendar year, as well as the type of personal information disclosed to those parties. Without your consent, UltraVPN will not share personal information with third parties outside of the Aura Group for their own direct marketing purposes.

10. Updates

UltraVPN may update this Policy from time to time and we will post updates to this page and update the “Last updated” date above. If we make updates that materially alter your privacy rights, we will also provide you with advance notice, via email or through the Services. If you disagree with the update, you may cancel your account. If you do not cancel your account before the date the update becomes effective, your continued use of our Services will be subject to the updated Policy.