RealVPN Privacy policy

Updated: March 18, 2019

 

We do not Identify You

At RealVPN, we strive to achieve the best possible user privacy and security. When you access our web resources or use our VPN service, you will share some information with us, which we use to make our products better, send relevant notifications and updates, and solve technical issues. This Privacy Policy describes what exactly we collect, how we use it, and whom we share it with. This Privacy Policy also depicts your rights and choices about your information, and how to contact us if you have any questions or concerns. In the overview below you can read about our most important privacy practices. Read the full Policy for more details. If you have any questions about this Policy, please contact us at [email protected]

Privacy overview

Our VPN service will never store or log your IP address beyond the duration of your VPN session, and we always delete your IP address once you disconnected from our VPN service.

We DO NOT keep logs of your online activities and never associate any domains, or applications that you access while you use RealVPN.

Creating an account for using Real VPN is optional – we never require you to register or otherwise provide us any personal information to download or use our VPN service.

While we always have your IP address un-identified while you connected to our VPN, remember that no VPN provider can control what other apps and services collect from your device or what cookies other websites or third parties place in your browser. For more information about how to exercise choices with respect to certain third-party cookies, please see the Third Party Advertising section below.

Security Overview

When the Real VPN is connected, we encrypt all traffic between your device and our servers.

Your web traffic on open free unsecured networks such as public Wi-Fi at cafés, airports, etc. is always securely encrypted when you connected to the Real VPN servers.

What does this Privacy Policy cover?

This Privacy Policy covers all versions of Real VPN product, including the Real VPN website. (collectively, the “Services”). The terms “Real VPN,” “we,” “us,” and “our” include Elestonia Trade OÜ, and our affiliates and subsidiaries. By using the Services, you agree to the terms and conditions of this Privacy Policy.

What Personal Information do we collect?

In this Privacy Policy, “Personal Information” is any information related to an identified or identifiable person. We obtain your Personal Information from various sources described below.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of not doing so. If you do not provide Personal Information when requested, you may not be able to get access to some features of our Services if that information is necessary to provide you with that feature.

There are two basic categories of Personal Information we collect:

  • Personal Information you decide to give us
  • Personal Information we automatically collect when you use our Services

Be assured that the Personal Information we may collect, including your email, IP address, username, or unique mobile ID, is never associated with any online activities you engage in while the Real VPN is connected. Also, when the Real VPN is connected, your IP address is stored in encrypted format for the duration of the session and is deleted after you disconnect from the VPN.

Personal Information You Choose to Give Us

When you use our Services, we collect the Personal Information that you decide to share with us. For example, if you purchase a subscription to Real VPN’s premium plans, and/or sign up to create an account, you may provide us with an email address and payment information. Remember that creating an account is always optional – we never require you to register or otherwise provide us any account-related information to download or use our products.

Also, if you make a payment by credit or debit card through the Services, your Personal Information will be collected by a third-party payment provider and NOT by us and will be the subject to the third-party’s privacy policy, rather than this Privacy Policy.

If you contact us directly, we may receive additional Personal Information about you. For example, when you contact customer support, we receive the contents of messages or attachments that you send to us and other information you decide to provide.

Personal Information We Collect Automatically When You Use the Services

When you download the Real VPN app, connect to the Real VPN, or visit our websites, we and our third-party service providers automatically collect some information about you and your device. Below is the list of the types of Personal Information collected when you use our Services:

When you launch the Real VPN app, before you connect to the VPN, we and our service providers collect some device-specific information, such as

  • the unique mobile ID
  • hardware model
  • OS version
  • Language
  • network information

We may also use, but never log or store, your IP address to derive your approximate (city-level) location. We use this information to provide you with the best quality of connection and improve the Services, troubleshoot, and perform analytics on our services. Our service providers may collect IP addresses for marketing attribution purposes.

When you connect to the Real VPN, we collect your IP address, immediately encrypt it and store it only while you are connected to our VPN. We immediately delete your IP address once you disconnected from the VPN. We do NOT associate your IP address with your online activities and we do not store or log your IP address after you disconnect from the VPN.

We do not record any specific website visits or app usage by any specific user. We do not keep logs of your online activities and never associate any domains or applications that you use with you, your device, or email.

Websites visited via our servers are collected and stored to:

  1. Perform analytics on our services measuring whether our users, in aggregate, are able to successfully access certain websites or apps;
  2. Troubleshoot service issues and improve service quality.

When you visit our websites

We and our third-party service providers and partners (e.g., Google Analytics) may automatically collect information from your device, sometimes by placing cookies, beacons, and similar technologies in your browser and on emails that we send you. We may use this information, for example, to ensure that the website functions properly, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. If you do not want any information to be collected through the use of cookies, you can use the simple procedure in most browsers that allows you to automatically disable cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Read more at www.allaboutcookies.org/manage-cookies/index.html. Keep in mind though, if you do not accept cookies, you may experience some inconvenience in your use of the website. To find out more about how to exercise choices with respect to certain third party cookies, including opting out of receiving such cookies, visit the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising at www.aboutads.info, or the Network Advertising Initiative at www.networkadvertising.org.

Your IP address may be collected during your visit of our websites but is not stored after your visit to our website. We may use your IP address to derive your approximate (city-level) location. Please see the “When you use Real VPN” section above to learn more about how we treat your IP address when you use our VPN products.

When you visit our websites, we may collect device-specific information, such as the unique mobile ID, device model, OS version, browser type, language, internet service providers and mobile network names. We only use it to provide and improve the website, troubleshoot, and perform analytics.

Our websites also use Google Analytics and Google Tag Manager which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information collected when you visit our website is in no way associated with your online usage when you’re connected to our VPN products.

How do we use your Personal Information?

We use your Personal Information to give you the best possible quality of products and services and have the ability to constantly improve them. Here are some examples of what we use it for:

To operate, maintain, improve and provide features of the Services, provide information that you request, respond to your comments and questions, and otherwise keep supporting our users.

Analyze aggregate usage trends and develop new products, services, features, and functionality.

Be able to contact you for administrative and informational purposes. For example, providing customer service or sending system updates, such as changes to our terms, conditions, and policies.

For marketing purposes, for example for marketing messages, or campaign attribution and optimization for user acquisition.

For our internal business purposes, such as audits, security, fraud monitoring and prevention.

To enforce our Terms of Service or other legal rights.

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, such as:

If we need your Personal Information to provide our services, including for account registration, to respond to your inquiries, or for customer support;

We have a legal obligation to use your Personal Information (such as to enforce our terms and conditions);

When we or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to troubleshoot issues, perform product improvement, conduct business analytics, conduct and optimize user acquisition, serve non-personalized ads, and otherwise monitor and improve the safety, security, and performance of our Service. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests;

If you otherwise consent to the processing of your Personal Information.

How do we share your Personal Information?

We only share your Personal Information in the way described in this privacy policy to provide and improve the Services, or if required to do so by law. As stated above, we do not log your browsing data and we delete your IP address when you disconnect from the VPN. Here are some examples of whom we share your information with and why:

To our third party service providers who provide services such as website hosting, payment processing, data analysis, information technology and related infrastructure provision, customer service, email delivery, fraud prevention, online advertising, auditing, and other services.

When you launch the Real VPN app, we may also use your IP address, which we automatically delete after you have disconnected from the VPN, to derive your approximate (city-level) location. When you are connected to the Real VPN, advertisers are prevented from seeing your IP address, however if you are using the free version of Real VPN we may share this approximate (city-level) location. If you are using the paid subscription to Real VPN this approximate (city-level) location will not be collected and will not be shared.

To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).

Again, we do not require you to provide us with any contact information in order to download or use our VPN product, we do not log or store your IP address after you have disconnected from our VPN servers, and we do not keep logs of your online activities. Therefore, we generally do not have Personal Information to share with law enforcement, and generally do not have the data to provide in response to law enforcement requests.

However, we may share what Personal Information we do have if required to do so by law or in the good faith belief that such action is appropriate:

  • under applicable law, including laws outside your country of residence;
  • to comply with legal process;
  • to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • to enforce our terms and conditions;
  • to protect our operations or those of any of our affiliates;
  • to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
  • to allow us to pursue available remedies or limit the damages that we may sustain.

If you use the paid subscription to Real VPN no information is shared with advertisers.

We may use and disclose aggregate information that does not allow to identify or otherwise relate to an individual for any purpose, unless we are prohibited from doing so under applicable law.

Third Party Services

This Privacy Policy applies only to the processing of your Personal Information by Real VPN operator. You may see third-party links or integrations on the Services. Keep in mind that this Privacy Policy does not describe, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

 

Security

Turning the Real VPN on encrypts all of the traffic between your device and our servers using powerful encryption algorithms. This means that your web traffic on unsecured networks such as public Wi-Fi at cafés, airports, etc. will be securely encrypted by Real VPN. This encryption also means that your current Internet Service Provider (ISP) will not be able to snoop on your web traffic and create records of the websites you are visiting while you are connected to the Real VPN servers; they will only see that all of your traffic is being sent to and from our servers.

We also maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.

 

Data Retention

As described above, we do not store your IP address beyond your VPN session and do not log your online activities.

We take all necessary measures to delete your Personal Information or keep it in a form that does not allow you to be identified when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

 

Your Rights and Choices

Marketing Communications. We do not require your email address or any contact information to use our Services. But if you do provide us an email address, from time to time we may send to this email address marketing email messages from us consistent with your choices. If you no longer want to receive such emails from us, you may opt-out via the “unsubscribe” link provided in each such email. Please be aware that, even after you opt out from receiving commercial messages from us, you may continue to receive necessary system messages regarding the Services.

Your Data Protection Rights (EEA). If you are located in the EEA, you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the “Contact Us” section below.

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide personal information through the Services. If we find out that a person under 16 has provided personal information, we will take steps to delete that information.

International Cross-Border Data Transfer

Real VPN services use servers hosted in the United States. Please note that we may be transferring your information outside of your region for storage and processing around the globe. By using our Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Updates to this Privacy Policy

From time to time we may make changes to this Privacy Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make solid changes, we may notify you through the Services or by sending you an email or other communication. We encourage you to read this Privacy Policy periodically to stay updated about our privacy practices. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or would like to exercise your rights to your Personal Information please contact us at [email protected] or Toompuiestee 21, Kesklinna district, Tallinn city, Harju county, 10137 Estonia.

If you are located in the EEA, Elestonia Trade OÜ is the entity responsible for the processing of your Personal Information.