Privacy Policy

This Privacy Policy (hereinafter referred to as "Policy") applies to Users (hereinafter referred to as "You" or "Users") of AI VPN (hereinafter referred to as "Application") built by Super Free VPN & AI Master Lab.

We are dedicated to maintaining the privacy and security of our users. By utilizing our AI VPN and related services, certain data is shared with us. This information is essential for the delivery and enhancement of our offerings, as well as for the distribution of alerts and updates, and to subsidize our free product via advertisements. Our aim is to be transparent regarding the collection, usage, and sharing of your data, which is the reason we have crafted this Privacy Policy. Should you have queries or concerns regarding this Policy, we urge you to reach out to us without delay at aivpnsupport@coolapps.tech.

## Security & privacy

- Every piece of data transmitted between your device and our servers is securely encrypted using TLS 1.2 and 256-bit AES encryption to ensure your information is protected.
- When connected to public Wi-Fi networks like those at airports, all your internet traffic is reliably encrypted by AI VPN, keeping it safe from prying eyes.
- Your real IP address is never recorded, stored, or shared by AI VPN, and we ensure to remove your actual IP address once your VPN session concludes.
- While you are using AI VPN, we guarantee not to link your real IP address or unique mobile identifier with any of your web browsing data or online activities.

## What information do we collect?

- This part outlines the different types of personal data, also known as 'personal information', that we gather about you. The collection of this information is not a constant process but occurs in specific situations related to certain products. For instance, as detailed in our VPN Products Privacy Notice, our VPN services collect only a minimal amount of personal data. It is explicitly stated that any browsing history from websites or applications accessed while using the VPN is not linked to any customer's personal details, unless the customer voluntarily discloses their identity and related information for a customer support inquiry.

### **Information You Provide to Us**

- **Account Information**: To access certain services, creating an account might be necessary or optional. During account registration, we collect data such as your name, username, email address, and password.
- **Billing and Payment Information**: For service purchases, you'll need to supply billing and payment details, including your billing name, contact information (such as street and email addresses), and payment method specifics. Payment processing and refund requests are handled by our payment partners using this fundamental billing information.
- **Communications and Submissions**: Any information you choose to share with us during communications (for example, through email, phone, or chat for support or inquiries about our services), or when you complete online forms, participate in surveys, give feedback, post comments on our website, engage in promotions, or submit data via our services, is voluntarily provided by you.

### **Information collected when you use our services**

- **Usage Information**: We gather data on your engagement with our services, including your visits and interactions with our websites or applications. This covers which AI VPN web pages or app functionalities are accessed, as well as the timing and duration of your service usage. To collect this information, we may employ cookies and/or other tracking technologies. Additional details are provided further below.
- **Device Information**: Information about the device you use to access our services is collected, including details on the browsers and AI VPN applications utilized. For instance, we might gather information such as device or mobile advertising identifiers, types of browsers, device configurations and settings, operating system versions, and network details including ISP name, carrier name, and signal strength, along with application version numbers. Cookies and other technologies may be used to collect this data. More information is available further below.
- **Diagnostic Information**: We gather details about the types of requests you make to our servers, including the nature of the request, the device and app used for the request, time stamps, and the URLs from which the requests are made.
- **Location Information**: We do not collect precise location data from your device's GPS or other sensors without explicit consent or a clear statement otherwise. However, for enhanced service quality, such as connecting you to the nearest and fastest VPN server, we might determine your approximate location using your IP address to infer a general latitude and longitude.
- **VPN-Specific Information**: Our VPN services are designed to ensure that no association is made between your account or identity and your activities during a VPN session. We do not keep records of the websites you visit or the apps you use through the VPN. Nonetheless, we will:
- Record the locations of the VPN servers you use.
- Gather diagnostic information similar to that mentioned above.
- If you're dissatisfied with the service, we may ask for your feedback on the connection quality or for more detailed survey responses. This feedback is not linked to any individual user.
- Assign a random ID, or 'hash', to your device upon the initial launch of our VPN apps. These hashes are not connected to your VPN browsing habits or personal identity but can be used to track individual device activity for analytical purposes.

### **Information Provided to Us by Third Parties**

- **Invitations to AI VPN Service**: If you are invited to utilize an AI VPN service, the individual extending the invitation may share your personal information with us, such as your email address or other forms of contact information.
- **Third Party Accounts**: Our services may permit the registration of an account through third-party platforms, like Google or Microsoft accounts. Should you opt for this registration method, the respective third party might provide us with certain details about you. The information shared by these third parties is subject to your control through the privacy settings associated with your account on their platforms.
- **Threat Information**: We receive data from trusted entities within the security industry aimed at enhancing our ability to provide, develop, test, and refine our services. This includes, but is not limited to, databases of malicious URLs, spam and phone number blacklists, and samples of malware. Occasionally, the information provided to us may include personal data as a collateral aspect.

### How do we use your information?

We employ the data we gather for several objectives, as detailed below. For individuals from the European Economic Area (EEA) or the U.K., we also outline the lawful basis for each type of data processing activity:

- **To Provide, Maintain, Troubleshoot, and Support Our Services**: Your information is utilized for this purpose based on the necessity to fulfill our contractual commitments to you. Examples include:
- Utilizing data on your bandwidth usage and service duration for our VPN products to deliver the service according to your subscription plan;
- Employing threat and device data in our digital threat platform to assess potential security risks; and
- Ensuring the smooth operation of our services in general.
- **For Billing and Payment Purposes**: We process your information to carry out billing administration and payment processing, actions required to meet our contractual obligations.
- **To Communicate with Users and Prospective Users**: We use your information to engage with you, which includes responding to your inquiries and providing you with updates and information about our services. This communication might be based on fulfilling our contract with you, your consent to the communication, or our legitimate interest in keeping you informed about our offerings.
- **To Improve Our Services**: Our aim is to constantly enhance and refine our offerings, driven by a legitimate interest in providing top-tier services and user experiences. To achieve this, we analyze usage, device, and diagnostic data to gain insights into aggregated user trends and engagement levels. This analysis helps us in making informed decisions, such as investing in our technical infrastructure to better accommodate regions with growing demand. Additionally, we utilize device and threat data for spam, threat, and scientific research to advance our threat detection capabilities and consider customer feedback to identify areas for improvement.
- **To Develop New Services**: We leverage your information with a legitimate interest in planning and creating new services. Customer feedback is invaluable in understanding the demand for new offerings and guiding our development efforts.
- **To Market and Advertise Our Services**: Your data is used to tailor, measure, and enhance our marketing and advertising efforts, based on our legitimate interest in presenting services you might find appealing. We assess referral sources to gauge our advertising's effectiveness and manage promotional activities, ensuring that your VPN browsing activity remains unrelated to these efforts.
- **To Prevent Harm or Liability**: Information is utilized for security purposes, including investigating security incidents and preventing fraud or abuse, to meet our legal obligations, protect vital interests, or prevent potential harm or liability to AI VPN and its users. This might involve using account, usage, and device information to detect unauthorized or abusive activities related to our services.
- **For Legal Compliance**: We process your information as necessary to comply with laws, legal procedures, or regulations and may be required to share essential data with business partners to fulfill contractual obligations or comply with court orders.

## How do we share your information?

### **In General**

Your information may be shared under the following conditions:

- **Following Your Directions or With Your Consent**: For instance, if you use a third-party account (like Google or Microsoft) to register for a service, we'll share information as directed by you with that third-party provider.
- **With Your Business Organization (For Business Services)**: If you access our services via a business account provided by your employer, other individuals within your organization, such as administrators, may access and manage the information needed to maintain your account and associated personal contact details. However, it's important to note:
- Business organizations are not privy to, nor do they receive any reports on, network or Internet usage data related to your VPN activities.
- Business organizations are not provided with any information from our identity products, such as credit report data, credit alerts, or other identity-related information unless you expressly consent to share such information for each specific request.
- **For Collaboration Purposes**: Some services enable users to interact or collaborate with each other. If you participate in these activities, your information may be shared accordingly.
- **With Vendors and Service Providers**: We collaborate with trusted third parties and partners to facilitate certain aspects of our services. To safeguard your data, we ensure these third parties adhere to strict confidentiality and data processing agreements, verify their security measures, and restrict our data sharing with them to only what is necessary for their assistance. These third parties may support us in areas such as:
- Payment processing for customers
- Analytics services for our offerings
- Sales and customer support provision
- Infrastructure maintenance for service delivery
- Marketing and advertising content distribution.

Your information may be shared under specific circumstances, including:

- **To a New Owner**: In the event that AI VPN or any of our assets are acquired or taken over by another party, your information could be transferred to the new owner to ensure the continuity of services.
- **Aggregated or De-Identified Data**: We may use and share data that has been aggregated or de-identified so it no longer identifies any individual user. This is done for purposes like regulatory compliance, research and analysis, marketing and advertising by us, and for other legitimate business activities.
- **Legal Compliance and Law Enforcement**: If legally required, your information may be shared to comply with the law, legal obligations, or to respond to lawful requests from law enforcement in connection with a criminal investigation or suspected illegal activities that could expose us, you, or other users to legal risks. We strictly limit the scope of information shared to what is necessary by law and actively challenge requests we believe to be unlawful or overly broad.
- **To Enforce Rights and Prevent Fraud and Abuse**: We may share your information in limited amounts to enforce our agreements, respond to claims against AI VPN, or protect against fraud and abuse aimed at AI VPN, our affiliates, or users.

### **Cookies and Other Tracking Technologies**

AI VPN utilizes a variety of technological tools within our services to gather data on website or app usage by users. These technologies include:

- **Cookies**: These are used by AI VPN or permitted third parties to identify visitors on our websites. The purposes of using cookies include:
- **Service Provision**: Essential cookies are crucial for the smooth operation of our services, enabling us to verify your identity and your access rights to certain resources.
- **Preference Storage**: Cookies store user preferences like language settings or username fields on login pages, and help tailor content to better suit your interests.
- **Analytics**: To understand user interaction and improve our services, cookies track actions such as page visits and advertisement effectiveness, aligning with our legitimate interests.
- **Security**: They play a role in detecting and preventing fraud, including certain types of online threats.
- **Advertising**: Used to support AI VPN’s advertising efforts, allowing third-party partners to display relevant ads and marketing across the internet.
- **Pixel Tags / Page Tags / Web Beacons / Tracking Links**: These tools track specific actions, such as when you visit a webpage, view an advertisement, open an email, or click a link. They can reveal actions taken, provide data like your IP address, and hint at your geographic location via your internet service provider.
- **Software Development Kits (SDKs)**: Employed in our mobile apps, SDKs enable interaction between our apps and the services provided by our business partners, enhancing functionality and service integration.

For detailed information on the use of these technologies, including how to manage preferences and opt-out options, please consult the cookie notice available on the specific product websites.

## **Security**

AI VPN implements various measures to safeguard your data, encompassing administrative, organizational, technical, and physical controls aimed at preventing unauthorized access, loss, or alteration of your information. Access to your Account Information and Services Information is strictly limited to employees whose job duties necessitate such access. Despite the robustness of our security protocols, it's important to acknowledge that no set of data security measures can offer absolute protection.

## **International Data Transfers**

AI VPN may relocate your personal data across international borders to support our operational needs. This includes sharing data with other entities within the AI VPN corporate family, as well as with our service providers and partners. It's important to note that legal standards and regulations concerning data protection may vary from one country to another. Specifically, personal information collected from individuals in the United Kingdom, Switzerland, or the European Economic Area (EEA) might be transferred to and processed in countries like the United States, where the data protection laws may differ from those in your home country.

Should you decide to change your country of residence, the AI VPN entity responsible for your data management may also change. Consequently, your personal data might be transferred to another company within our network, in alignment with your new residency.

For our VPN product users residing in the UK or EEA: if you opt to route your Internet traffic through servers located in countries not recognized as offering adequate data protection by the UK or EEA standards, you are acknowledging that these data transfers are conducted based on your explicit direction and consent.

## **Data Retention**

Regarding our VPN services, AI VPN does not gather or keep any data on your browsing activities during your use of the VPN. We hold onto your personal information only for the duration necessary to deliver our services to you, or as long as your account or subscription remains active. Additionally, we might retain personal information if legally obligated, or for legitimate purposes like detecting and preventing abuse, or safeguarding against legal actions. To ensure data protection against loss, residual copies of your personal data may be kept in our backup systems for a temporary period.

## **Your Rights**

Depending on where you live, you may have specific legal rights regarding the personal data we hold about you. These rights, subject to legal exceptions and limitations, can include:

- **Accessing and obtaining a copy** of your personal data;
- **Correcting** inaccuracies in your personal data;
- **Restricting the processing** of your personal data;
- **Objecting** to the processing of your personal data at any time;
- **Erasure** of your personal data;
- **Data portability**, allowing you to move your data;
- **Withdrawing consent** for data processing you previously agreed to, such as opting out of marketing communications;
- **Filing a complaint** with a data protection authority;
- **Requesting information** on the categories of personal data collected, disclosed, or sold, including the sources of such data, the purpose of collection or selling, and the categories of third parties with whom the data is shared. This information may be outlined in this Privacy Policy.

You might be able to exercise some of these rights directly through the settings and tools available in our services. For instance, updating your user account details can often be done through the app's account settings. Opting out of marketing communications can usually be achieved by clicking an “opt out” or “unsubscribe” link in the messages.

Although some browsers send "do-not-track" signals, we do not currently respond to these signals. To exercise any of your rights, you're encouraged to contact us via the details provided in the “Contact Us” section. We may need to verify your identity in accordance with the law before proceeding with your request. You may also have the option to appoint an authorized agent to make requests on your behalf, but this requires written permission or a power of attorney, and we may need to verify both your and your agent’s identity before proceeding.

## **Your California Privacy Rights**

The details provided outline the types of personal information AI VPN collects, how it's processed, and with whom it may be shared, including service providers and other entities. If you wish to exercise your rights to access specific pieces of your personal information, or any other rights applicable to you as mentioned above, you should look into the 'Contact Us' section provided at the end of this document for guidance on how to make such requests.

AI VPN explicitly states that it does not 'sell' or 'share' personal information for direct monetary gain. Nonetheless, due to the broad interpretation of 'sell' and 'share' under the California Consumer Privacy Act (CCPA), the use of third-party advertising services in support of our website, marketing initiatives, and mobile apps might be considered as 'selling' or 'sharing' as per California law. To manage your preferences regarding personalized ads, or to understand more about the cookies we use, you are encouraged to visit the cookie policy page of AI VPN. There, you'll find detailed lists of cookies, notices, and information on app-specific advertising services, allowing you to tailor your ad preferences.

## **Compliance with children's online privacy protection act**

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information on our site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

## **Privacy Policy Updates**

AI VPN reserves the right to modify this Privacy Policy as needed due to factors like legislative changes, shifts in industry standards, or adjustments in our business practices. Whenever updates are made, they will be reflected on this page, and we will revise the "Last updated" date accordingly. For changes that significantly affect your privacy rights, AI VPN commits to providing advance notification, either through email or directly via our services. Should you find any such updates unacceptable, you have the option to terminate your services account. Failing to cancel your account before the effective date of these changes will imply your consent to continue under the terms of the revised Privacy Policy.

## **Contact Us**

AI VPN anticipates that this Privacy Policy will adapt and change over time. We greatly value feedback from our users regarding our privacy practices.

Should you have any inquiries about this Privacy Policy, the practices of this website, or your interactions with this site, please don't hesitate to get in touch with us at aivpnsupport@coolapps.tech. Your feedback and questions are essential to us in ensuring that our privacy practices meet your expectations and regulatory standards.