This policy uses the term " personal data " to refer to information related to identified or identifiable natural persons, and is protected as personal data in accordance with applicable data protection laws.
This strategy covers the data processing practice of Simplepenguinagent VPN .
In this policy, "we", "we" and "ours" refer to the specific companies listed above, which provide services for you and are responsible for processing your data according to this policy.For mobile applications, you can identify the company by viewing the companies that provide the application or viewing their terms of service on the download page.
This section introduces all kinds of information about you that we collected from you.This information is not collected in all cases, but only in specific cases.To understand the context in which collection takes place, please refer to Section 2 (How do we use your information?）。For more information about some mechanisms we use to collect this information, such as cookies, see Section 4 (Tracking Technology and Cookies).
● Account information.Some services require or allow you to create accounts to access them.As part of registering an account, we may collect information such as your name, user name, email address and password.
● Bill and payment information.In order to purchase services, you may need to provide us with detailed information, such as bill name, bill contact information (street address, email address) and payment method details.
● authentication information.Some services require you to verify your identity when creating an account to access them.For this reason, we may collect information such as email address.
● Communication and submission.When you contact us, you can choose to provide us with information (for example, get support through email or inquire about our services), including when you fill out online forms, reply to surveys, provide feedback, participate in promotions or submit information through our services.
● usage information.We collect information about how you interact with our services, such as how much bandwidth you use, when and when you use our services.
● equipment information.We collect information from and relate to the devices you use to access our services.For example, we may collect device identifier, browser type, device type and settings, operating system version, mobile, wireless and other network information (such as Internet service provider name, operator name and signal strength) and application version number.
● Diagnostic information.We may collect information about the nature of your request to the server (for example, the requested content, information about the device and application used to make the request, timestamp and reference URL).However, we will not record any information that associates your identity with VPN browsing activities.We don't keep any records showing what you are browsing or accessing through the VPN connection.
● Location information.We may collect your location information based on various sources (such as GPS of equipment) or approximate longitude and latitude calculated according to your IP address.
● Recommended.If you are invited to use our service, the person who invited you can submit your personal data, such as your email address or other contact information.
● Third party accounts.Some services may allow you to register your account with a third-party account, such as a Google or Microsoft account.If you do this, the third party may send us some information about them.You may be able to control what information they send to us through the privacy settings of this third-party account.
● Threat information.We may receive information from well-known members of the security industry, and the information provided by these members can help us provide, develop, test and improve our services (for example, malicious URL list, spam blacklist, phone number blacklist and sample malware).Some of the information may accidentally contain personal data.
Unless you have a contractual obligation to us, you usually have no obligation to disclose personal data to us.However, we need to collect and process some necessary or legally required information in order to provide services for you or establish a contractual relationship with you in other ways.
We will use the collected information for various purposes as described below.
● To provide, maintain, troubleshoot and support our services.We use your information as necessary to fulfill our contractual obligations to you.Example: use information about how much bandwidth you use and how long you use our services to provide services according to the plan to which you have subscribed;Use threat and equipment information to determine whether certain items pose potential security threats;Use location information to connect you to the nearest and fastest VPN server;And use the usage information to solve the service problems you reported to us and ensure the normal operation of our service.
● used for billing and payment.We use your information to perform bill management activities and process payments, which are necessary to fulfill our contractual obligations.
● Communicate with users and potential users.We use your information to communicate with you, including responding to your requests and sending you information and updates about our services.We may do this to fulfill our contract with you, because you agree to this communication, or because we have a legitimate interest in providing you with information about our services.
● In order to improve our service.We hope to provide you with the best service and user experience, so we have a reasonable interest in continuously improving and optimizing our services.To this end, we use your information to understand how users interact with our services.Example: We analyze some usage, equipment and diagnostic information to understand the overall usage trend and the user's participation in our services (for example, investing in technology infrastructure to better serve the regions with increasing user demand);We may use equipment and threat information to conduct spam, threats and other scientific research to improve our threat detection capabilities;We will review customer feedback to understand that we can do better.
● Develop new services.We have a legitimate interest in using your information to plan and develop new services.For example, we may use customer feedback to learn about new services that users may want.
● To market and publicize our services.We may use your information to provide, measure, personalize and enhance our advertising and marketing according to our legitimate interests in providing services that may be of interest to you.For example, we may use information such as who or what led you to our service to know how effective our advertisement is;We may use information to manage promotional activities, such as sweepstakes and recommendation programs.Our VPN products will not use your VPN browsing activities for these purposes, and we will not keep any records showing what you are browsing or accessing through the VPN connection.
● To prevent injury or liability.We may use information for security purposes (such as investigating security issues or monitoring and preventing fraud) and prevent abuse.We may do this to comply with our legal obligations and protect the vital interests of individuals, or because we have a legitimate interest in preventing harm or taking responsibility for us and our users.For example, we may use account, usage and equipment information to determine whether an entity is engaged in abusive or unauthorized activities related to our services.
● In order to comply with the law.We will use your information internally according to applicable laws, legal procedures or regulations.To understand how we share your information with third parties for legal compliance purposes, please refer to Section 3.1 below.We will also use your information to enforce our legal rights and resolve disputes.
We may disclose your information under the following circumstances:
● Follow your instructions or consent.For example, some services may allow you to register an account with a third-party account, such as a Google or Microsoft account.If you choose to do so, we will share information with third-party account providers.
● affiliated companies and third-party service providers.In order to help us provide certain services, we cooperate with members and trusted third parties.In order to protect your data, we have established appropriate confidentiality and data processing clauses with these third parties, reviewed their security practices, and limited information sharing to the extent that they helped us.The activities that the third party helps us to carry out include:
Handle customer payment.
○ Provide analysis of our services
○ Provide sales and customer support
○ Maintain the infrastructure needed to provide our services
○ Provide our marketing and advertising content
○ Put in advertising content
Low to the new owner.If the ownership or control of all or part of our services, assets or business changes, we may transfer your information to the new owner.
● summarize or cancel the identified data.We may use and share aggregated data and de-identified data, so that it will no longer disclose the identity of individual users for compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.
● abide by legal procedures and laws.We strictly protect the privacy of users.For our VPN products, we protect your privacy by ensuring that we will not record or record your online activities through the VPN connection in any way that may contact you, which means that we don't have any law enforcement and government agencies that can share data with the law and require information about what you are doing through the VPN connection.Subject to the above provisions, if applicable laws require us to share your information, we may share your information;Comply with our legal obligations;Comply with legal procedures;And respond to effective law enforcement requirements related to criminal investigation or suspected or suspected illegal activities, which may make us, you or any other users of us bear legal responsibilities.If we share your information for these purposes, we will limit the shared information to what is legally necessary, and challenge the request for information that we consider illegal, excessive or otherwise invalid.
● To enforce our rights and prevent fraud and abuse.We may share a limited amount of your information to execute and manage our agreements with customers and users, and to respond to our claims.We may also share your information to prevent fraud and abuse to us, our members, users and others.
We may advertise to users in some areas.The advertisements we display in the service are provided by advertisers who have relations with us or by third-party advertising networks (such as Google).To display the third-party advertisement in our application, we integrate a software development kit (SDK) into it, which contains the software code provided by the advertising network.
We provide limited personal data about you to such third-party advertising networks so that they can provide services.For example, some advertising networks may collect information through their SDK, such as your mobile advertising identifier, IP address and device information, in order to provide you with "personalized" advertisements (which they think are more relevant to you) and evaluate your reaction to these advertisements.If you use VPN connection, your IP address is hidden from the advertising network and replaced by the IP address of our VPN server.
Although we ask you not to use advertisement interceptors to block the display of third-party advertisements, because this is how we support our free services, if you do use advertisement interceptors, our services will continue to run.
We use various technologies in our services to help us collect information.For convenience, we call them "tracking technologies", although they are not always used to track individuals, and the collected information is in an unrecognizable form and does not refer to any personal data.Tracking techniques include:
Cookies are small pieces of text stored on the devices you use to access our services.Cookies enable us (or a third party that allows us to set cookies on your device) to identify duplicate users.Cookies may expire after a period of time, depending on their use.
These are small hidden images and code blocks hidden in web pages, advertisements and our e-mails, which allow us to determine whether you perform specific actions.When you visit a page, advertisement or email or click a link, these items will tell us that you have visited the page, opened an email or clicked a link.
SDK or software development kit is the software code provided by our business partners, which enables our software to interact with the services provided by our partners.For example, in some mobile applications, we may use SDK to enable our applications to deliver advertisements from advertising networks.Sometimes, these interactions involve business partners collecting some information from the devices running the software.
● In order to provide our services.Some cookie are necessary for the normal operation of our service.For example, cookie allow us to verify your identity and access to resources.
● Save your preferences.Cookies can store your preferences, such as language preferences or whether to pre-fill your user name in the login form.We may also use them to optimize the content displayed to you.
● used for analysis.Cookies are used to tell us how users interact with our services, so we can improve their working methods (such as which screens or web pages you visit and whether our advertisements are effective) for legitimate interests.
● For safety.Cookies can enable us and our payment processors to detect certain frauds.
● used for advertising related purposes.We advertise our services online with the help of third parties, who display advertisements and markets about us on websites on the Internet.
We may allow our business partners to place certain tracking technologies in our services.These partners use these technologies for the following purposes:
● In order to provide our services.Some business partners who help us provide services may use these technologies to support these efforts.
● for Analytics.Help us understand how you use our services.
● used for marketing.To help us sell and publicize our services to you, including on third-party websites.Cookie are related to this, which can be used to measure our advertising effect, relate your actions on our advertising with your actions on our services, and provide advertisement repositioning (advertising based on your past interaction with our services) and similar audiences.
● Advertisements should be placed.Advertising networks may use these technologies to display advertisements that they think are more relevant to you.For more information, see the section "Display ads" above.
● Our Cookies: Most web browsers and some mobile devices enable you to manage cookie preferences, including deleting cookies and preventing cookies from being set on these browsers or devices.Visit the Help section of your mobile device to learn how it controls Cookie.Please note that deleting or blocking some Cookie may adversely affect the normal operation of our service.
● Third-party advertising Cookie: For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:
○ Online advertising plan exit page
Digital advertising alliance exit page
○ Your online choice (for Australian residents)
○ Your online selection (for EU residents)
To exit Google Advertising Personalization, please visit Google Ads Settings page.We do not provide these exit mechanisms, and we are not responsible for their availability or operation.Please note that you may still see non-personalized advertisements after choosing to quit personalized advertisements.
● Google Analytics: We use Google Analytics to help us understand how users use our services.If you don't want to participate in Google Analytics, Google will provide Google Analytics exit browser plug-in.
We have adopted a series of management, organization, technology and physical protection measures to protect your data from unauthorized access, loss or modification.We are constantly striving to improve such safeguards.
We may transfer your personal data to a country other than the country where you live.We do this to promote our operation, and the assignee includes our group companies, service providers and partners.The laws of other countries may be different from those of your place of residence.
We usually have your personal data within the time required to provide services for you or in our account.If required by law or for legitimate interests (such as detection and prevention of abuse) and to protect us from legal requirements, we may also keep personal data.The remaining copies of personal data can be stored in the backup system as a security measure to prevent data loss.According to the above regulations, if your personal data is no longer needed, we will ensure that it is safely deleted or stored in some way, which means that we will no longer use them.
Depending on the country where you live, you may have some legal rights to the personal data we maintain.Subject to the exceptions and restrictions provided by applicable laws, these rights may include:
● Access and receive copies of your personal data;
● Correct your personal data;
● Restrict the processing of your personal data;
● Oppose the handling of your personal data at any time;
● Delete your personal data;
● Data portability;
● Withdraw any consent you have previously given to data processing (for example, opt out of market communication);
● Complain to the data protection agency;
Please note that your rights and choices will vary according to your location, and some requests may exempt certain information according to applicable laws.
You can use the settings and tools provided in our service to exercise some of these rights.For example, you can update your user account details through the relevant account settings screen of our application.You can also choose not to receive our marketing information by clicking the "opt out" or "unsubscribe" link in such communication.
Otherwise, if you wish to exercise any of these rights, you can contact us with the details in the Contact Us section below.As permitted by law, we may ask you to verify your identity before taking further action on your request.
Due to the lack of standardization on how to interpret this signal, we do not respond to the "Do not track" signal sent by browsers or mobile applications at present.Learn more about Don't Track.
California law allows California residents to request and obtain a list of third parties whose "personal information" (if any) has been disclosed to them according to California Civil Code 1798.83, their direct marketing purpose in the last calendar year, and the types of personal information disclosed to these parties.For information on where to send such requests, see the Contact Us section below.Please note that we will not share personal information with third parties for direct marketing purposes without your prior consent.
According to the California Consumer Privacy Act (CCPA), you may have the right to choose not to sell your personal information.CCPA broadly defines "sales" to include allowing third parties to receive certain information (such as Cookie) to place personalized advertisements on our services.
We will not "sell" (as defined by CCPA) your personal information except in the case of some product versions supported by personalized advertisements.Advertising (including personalized advertising) enables us to offer some products free of charge, offer preferential treatment related to you, and because we believe that everyone (regardless of their situation) has the opportunity to obtain safe and private access to the Internet.Personalized advertisements can display advertisements that are more relevant to you.
Depending on the services you use and how you use them, we may "sell" (according to California law) the following types of personal information for advertising purposes:
Identifiers (such as advertisement identifiers and Cookie)
● Internet or other network or device activities (for example, which of our applications are you using)
● approximate geographical location information
To select us to use your information for this purpose, please visit: Do not sell my personal information.Please note that we will not intentionally sell personal information of minors, and at the age of 16, there is no legal requirement for affirmative authorization.
● To provide you with the categories of your personal information collected or disclosed by us in the past 12 months, the source categories of such information, the commercial or commercial purpose of collecting or selling your personal information and the categories of the third parties contacted with it.This information is provided in this notice;
● Provide access to or a copy of some information we hold about you;
● Delete some information we have about you.
You may also have the right to obtain information about the economic incentives we provide for you, if any, and the right not to be discriminated against when exercising certain rights (according to CCPA).
According to applicable laws, certain information may not be subject to such requirements.For example, we need certain types of information so that we can provide services to you and comply with applicable laws.
When you exercise certain rights, we may take reasonable steps to verify your identity before meeting your request (for example, verify your email address or payment method).If you ask us to delete some information, you may no longer be able to access or use our services.
You can also specify an authorized agent to submit certain requests on your behalf.In order to authenticate the authorized agent, you must provide the authorized agent with a signed written permission to make such a request or authorization.We may also authenticate with you before processing the request of the authorized agent.
If you want to know more about your legal rights under California law, or want to exercise any of them, please contact us at the address listed in the "Contact Us" section below.
California Consumer Privacy Act (CCPA) requires us to make certain disclosures to California residents, including the types of personal information we collect, the purpose we use this information, the types of personal information sources and the types of third parties with which we share personal information.This section lists this information in the manner specified by CCPA, but it is not fundamentally different from the information in the rest of this policy.
Sources of personal information
All categories of personal information we collect come from the following sources:
● You (through voluntary submission or automatic collection (for example, when you use our services))
● Third parties (such as service providers, other users or marketing partners, who may lead you to our services)
Types of personal information collected and with whom do we share information
● Identifier (e.g. name, account username, email address)
● Business information (e.g. transaction data)
● Financial and transaction data (such as payment method details)
● Internet or other network or device activities (such as application usage and interaction with our services)
Geographic location information (e.g., city and state based on IP address)
● demographic information (such as age and gender)
● Customer service information (such as support request)
● Survey responses and other research information
● Other information that identifies you or can reasonably be associated with you Third-party classification with whom do we share your personal information As mentioned above, the collected personal information categories can be shared with the following third-party categories:
● our members
● Third-party service providers that perform services on our behalf (e.g., payment processors, analysis providers)
● Third-party advertising networks (such as Google)
● Third parties for legal purposes (e.g. responding to legal proceedings)
● Other people with your consent or instruction
We use your personal information for business and business purposes
As mentioned above, the collected personal information categories are used for the following purpose categories:
● To provide, maintain, troubleshoot and support our services.
● used for billing and payment.
● Communicate with users and potential users.
● In order to improve our service.
● Develop new services.
● To market and publicize our services.
● To prevent injury or liability.
● In order to comply with the law.
Section 2 above provides more information about these categories, including use case examples.
Our service is not suitable for or for minors.In this case, a minor is a person under the age of 16 (or the lower age that may be applicable in a certain jurisdiction).We will not intentionally collect personal data of minors or allow them to use our services.If we find that we have collected personal data from minors, we may delete the data without notice.
Simplepenguinagent VPN Term
Addressee: French Works Department
Room 020 , 9/F , Block G , Kwai Chung Shing Industrial Building (Stage 2 ), 42-46 Tai Lin Pai Road, Kwai Chung, NT , Hong Kong