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Effective date: Since September 30, 2024.
Privacy Policy
1.1. At Priority VPN, we are committed to protecting your personal information and respecting your privacy. This Privacy Policy is intended to help you understand the types of information we collect, how we use and store that information, and the circumstances under which we may disclose it. It also outlines the measures we take to safeguard your information and how you can exercise your rights in relation to your information.
1.2. This Privacy Policy is directed towards individuals (data subjects) who are:
1.2.1. Users who access our Site, the Apps or the Services; and
1.2.2. Users who have purchased a subscription to the Services or have been granted a free trial period, via the Apps available by the Third-Party Platforms.
1.3.By using and/or accessing the Services, you are agreeing on behalf of yourself or those you represent (“you” or “user” or through any second person pronouns, such as “yours” etc) to comply with and to be legally bound by this Privacy Policy in its entirety.
1.4. As far as this Privacy Policy forms an integral part of our Terms of Service (the “Agreement” or the “Terms”), users agree with the Privacy Policy in accordance with the Terms. Unless otherwise expressly stated by this Privacy Policy, all definitions herein shall be understood, as they appear in the Company’s Agreement.
1.5. If you do not agree with this Privacy Policy, you shall refrain from accessing and/or using our Services and you shall consider the use of our Services no longer available to you.
1.6. We are fully committed to respecting privacy and to protecting any information that our users provide. Your privacy and security are both our highest priorities, and we make every effort to ensure that all the information provided by you is protected. We follow and comply with best practices and regulations in the sphere of privacy including but not limited to General Data Protection Regulation (the “GDPR”).
1.2. This Privacy Policy is directed towards individuals (data subjects) who are:
1.2.1. Users who access our Site, the Apps or the Services; and
1.2.2. Users who have purchased a subscription to the Services or have been granted a free trial period, via the Apps available by the Third-Party Platforms.
1.3.By using and/or accessing the Services, you are agreeing on behalf of yourself or those you represent (“you” or “user” or through any second person pronouns, such as “yours” etc) to comply with and to be legally bound by this Privacy Policy in its entirety.
1.4. As far as this Privacy Policy forms an integral part of our Terms of Service (the “Agreement” or the “Terms”), users agree with the Privacy Policy in accordance with the Terms. Unless otherwise expressly stated by this Privacy Policy, all definitions herein shall be understood, as they appear in the Company’s Agreement.
1.5. If you do not agree with this Privacy Policy, you shall refrain from accessing and/or using our Services and you shall consider the use of our Services no longer available to you.
1.6. We are fully committed to respecting privacy and to protecting any information that our users provide. Your privacy and security are both our highest priorities, and we make every effort to ensure that all the information provided by you is protected. We follow and comply with best practices and regulations in the sphere of privacy including but not limited to General Data Protection Regulation (the “GDPR”).
1. Introduction
For the purposes of this Privacy Policy, the following terms shall have the following meanings:
2.1. Personal data: any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
2.2. Data subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
2.3. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2.4. Controller: the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
2.5. Processor: a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
2.6. Consent: any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
If applicable and unless otherwise expressly stated in this Privacy Policy, all definitions herein shall be understood, as they appear in the Terms and Conditions and in the GDPR.
2.1. Personal data: any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
2.2. Data subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
2.3. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2.4. Controller: the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
2.5. Processor: a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
2.6. Consent: any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
If applicable and unless otherwise expressly stated in this Privacy Policy, all definitions herein shall be understood, as they appear in the Terms and Conditions and in the GDPR.
2. Definitions
3.3. For any inquiries about this Privacy Policy or in relation to your personal data, please contact us through our Contact Form. Please insert this as an image. It should not be copiable and it should be indexed in Google.
3. General Information
4.1. Our guiding principle is to collect only the minimal data required to operate our Services. We have a strict No Logs Policy and do not intentionally collect logs of your activity, including browsing history (which websites you visit), traffic destination, data content, DNS queries, session lengths or connection logs.
4.2. By using our Services, the following information may be collected:
4.2.1. Hashed user data, which is anonymized and encrypted in order to provide our Services and may be used by our third-party service providers for the payment and connectivity purposes.
4.2.2. Contact data: when communicating with the Company we might process personal data, which you may willingly provide to us through our Contact Form, for example: name, email address, etc. Provision of personal data, described in this clause is optional. We keep records of any correspondence you submit to us through our Site, Apps or Services, along with our response. This enables our staff to provide the best possible customer support experience.
4.2.3. Marketing and analytical data: We also automatically record information about your usage of the Site and attendance statistics, including actions taken, your page response times, number of visits and page interaction information (such as scrolling, clicks, and mouse hovers), date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to clicks, sources, events, contacts and other feature usage and marketing and analytical data. This data is mostly collected for analytical purposes, as described below, and there is no technical capability to identify you with this data.
4.2.4. Technical data, including your browser type and version, time zone setting, location, browser versions, Apps version, operating system and platform, and other information about the devices you use to access the Site. This data is collected for statistical purposes, as further described below, and there is no technical capability to personally identify you with this data.
4.3. If you use our Apps for the iOS, MacOS, Android mobile operating systems (or other operating systems where applicable) through Third-Party Platforms such as the App Store and Google Play, you may be required to provide certain personal information in order to use the Apps. Please note that such information is requested by App Store, Google Play and other Third-Party Platforms, not by us. We encourage you to review the privacy policies of App Store and Google Play before providing the requested personal information.
4.2. By using our Services, the following information may be collected:
4.2.1. Hashed user data, which is anonymized and encrypted in order to provide our Services and may be used by our third-party service providers for the payment and connectivity purposes.
4.2.2. Contact data: when communicating with the Company we might process personal data, which you may willingly provide to us through our Contact Form, for example: name, email address, etc. Provision of personal data, described in this clause is optional. We keep records of any correspondence you submit to us through our Site, Apps or Services, along with our response. This enables our staff to provide the best possible customer support experience.
4.2.3. Marketing and analytical data: We also automatically record information about your usage of the Site and attendance statistics, including actions taken, your page response times, number of visits and page interaction information (such as scrolling, clicks, and mouse hovers), date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to clicks, sources, events, contacts and other feature usage and marketing and analytical data. This data is mostly collected for analytical purposes, as described below, and there is no technical capability to identify you with this data.
4.2.4. Technical data, including your browser type and version, time zone setting, location, browser versions, Apps version, operating system and platform, and other information about the devices you use to access the Site. This data is collected for statistical purposes, as further described below, and there is no technical capability to personally identify you with this data.
4.3. If you use our Apps for the iOS, MacOS, Android mobile operating systems (or other operating systems where applicable) through Third-Party Platforms such as the App Store and Google Play, you may be required to provide certain personal information in order to use the Apps. Please note that such information is requested by App Store, Google Play and other Third-Party Platforms, not by us. We encourage you to review the privacy policies of App Store and Google Play before providing the requested personal information.
4. Collection and processing of your personal data
5.1. We have implemented physical, procedural, and technical security measures to prevent any loss, misuse, or unauthorized access to your personal data. However, no data security measures can offer completely infallible protection. For this reason, our guiding principle is to collect minimal data.
5.2. Your personal data is retained for a limited period in accordance with applicable data protection law (for as long as we have your consent or a legitimate reason or other legal basis for holding such data). You may request the deletion of your data by sending a valid request of erasure in accordance with GDPR.
5.3. Third-party service providers may have controlled access to relevant data to help us process support requests and otherwise assist us in providing our Services. All third-party service providers have confidentiality and data processing obligations to keep the data confidential and not use it for any other purpose.
5.4. The Third-Party Platforms (i.e. App Store and Google Play) are solely responsible for the data that they collect in order to provide you with our Apps and in order for you to purchase subscriptions to our Services. If you use our Apps for the iOS, MacOS, Android and other operating systems through Third-Party Platforms, you may be required to provide certain personal information in order to use the Apps and purchase subscriptions to our Services. Please note that such information is requested by Third-Party Platforms, not by us. We encourage you to review the privacy policies of App Store and Google Play before providing the requested personal information. We do not receive any of your personal data from the said Third-Party Platforms. For any inquiries or information regarding the said collection and processing of personal data, you may contact directly the respective Third-Party Platform.
5.2. Your personal data is retained for a limited period in accordance with applicable data protection law (for as long as we have your consent or a legitimate reason or other legal basis for holding such data). You may request the deletion of your data by sending a valid request of erasure in accordance with GDPR.
5.3. Third-party service providers may have controlled access to relevant data to help us process support requests and otherwise assist us in providing our Services. All third-party service providers have confidentiality and data processing obligations to keep the data confidential and not use it for any other purpose.
5.4. The Third-Party Platforms (i.e. App Store and Google Play) are solely responsible for the data that they collect in order to provide you with our Apps and in order for you to purchase subscriptions to our Services. If you use our Apps for the iOS, MacOS, Android and other operating systems through Third-Party Platforms, you may be required to provide certain personal information in order to use the Apps and purchase subscriptions to our Services. Please note that such information is requested by Third-Party Platforms, not by us. We encourage you to review the privacy policies of App Store and Google Play before providing the requested personal information. We do not receive any of your personal data from the said Third-Party Platforms. For any inquiries or information regarding the said collection and processing of personal data, you may contact directly the respective Third-Party Platform.
5. How We Protect, Safeguard and Retain Your Personal Data
6.1. All processing of your personal data is performed in accordance with the GDPR. We process your personal data for the purposes listed below and on the legal basis indicated below. This clause is further structured as follows - first you will find the legal basis for the processing of your personal data and then the indicative purposes for which the Company may use your personal data under that legal basis. If the Company will ask to provide any other personal data not described above, then such information, the purpose and legal basis for the collection and processing, will be communicated to the user at the point of collecting the personal data.
6.2. Legal basis No. 1 – for compliance with legal obligations (Art. 6 para. 1 lit. C GDPR).
In the course of its business, the Company is required to comply with various laws and regulations. In order to comply with such regulations, the Company will collect and process personal data. Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; to address any legal claims, disputes, or investigations; or to protect our or our users’ rights or property.
6.3. Legal basis No. 2 – for the performance of our contractual obligations (Art. 6 para. 1 lit. B GDPR).
In order to perform our services (ensure general performance of our services, performance and administration of the Company), provide you with access to our Site and Apps, fulfil our contractual obligations, improve our Site and services, and to provide you with the possibility to enter into contractual arrangements with us we will process personal data. Your personal data may be also used in order to send you periodic emails: this might be for security reasons, to respond to any queries, requests, or technical issues.
6.4. Legal basis No. 3 – legitimate interests pursued by the Company (Art. 6 para. 1 lit. F GDPR).
Data processing might take place to maintain the legitimate interests of the Company or a third party. The following purposes of processing personal data, for example, are covered by such legitimate interest:
- Monitoring and prevention of fraud, misuse (e.g. for illegal purposes), and any other type of criminal activity.
- Identification and examination of different possible vulnerabilities of the Site and Apps.
- Measures for protecting our users, as well as safeguarding network and information security, also measures to protect our employees, contractors, and property of the Company.
- Providing information security and IT security on our Site and Apps and safeguarding our network.
- Developing new features for our users.
6.5. Legal basis No. 4 – your consent (Art. 6 para. 1 lit. A GDPR).
If you have given us your consent to process your personal data, processing will only take place in accordance with the purposes defined and to the extent agreed in such declaration of consent. You have a right to withdraw your consent at any time if you no longer agree to the processing by writing an e-mail to the Company. Please note that the withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal. By checking the respective box as a part of the registration process (or giving consent in other similar way) or by utilizing the Site or Apps, the user agrees to this Privacy Policy and agrees to the data processing as described herein.
6.2. Legal basis No. 1 – for compliance with legal obligations (Art. 6 para. 1 lit. C GDPR).
In the course of its business, the Company is required to comply with various laws and regulations. In order to comply with such regulations, the Company will collect and process personal data. Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; to address any legal claims, disputes, or investigations; or to protect our or our users’ rights or property.
6.3. Legal basis No. 2 – for the performance of our contractual obligations (Art. 6 para. 1 lit. B GDPR).
In order to perform our services (ensure general performance of our services, performance and administration of the Company), provide you with access to our Site and Apps, fulfil our contractual obligations, improve our Site and services, and to provide you with the possibility to enter into contractual arrangements with us we will process personal data. Your personal data may be also used in order to send you periodic emails: this might be for security reasons, to respond to any queries, requests, or technical issues.
6.4. Legal basis No. 3 – legitimate interests pursued by the Company (Art. 6 para. 1 lit. F GDPR).
Data processing might take place to maintain the legitimate interests of the Company or a third party. The following purposes of processing personal data, for example, are covered by such legitimate interest:
- Monitoring and prevention of fraud, misuse (e.g. for illegal purposes), and any other type of criminal activity.
- Identification and examination of different possible vulnerabilities of the Site and Apps.
- Measures for protecting our users, as well as safeguarding network and information security, also measures to protect our employees, contractors, and property of the Company.
- Providing information security and IT security on our Site and Apps and safeguarding our network.
- Developing new features for our users.
6.5. Legal basis No. 4 – your consent (Art. 6 para. 1 lit. A GDPR).
If you have given us your consent to process your personal data, processing will only take place in accordance with the purposes defined and to the extent agreed in such declaration of consent. You have a right to withdraw your consent at any time if you no longer agree to the processing by writing an e-mail to the Company. Please note that the withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal. By checking the respective box as a part of the registration process (or giving consent in other similar way) or by utilizing the Site or Apps, the user agrees to this Privacy Policy and agrees to the data processing as described herein.
6. Our Legal Basis and Purposes for Using Your Personal Information
7.1. For user experience, marketing and analytics purposes, we use several analytics services, including from third-party service providers. These services may use small data files, commonly known as cookies, mobile identifiers, and other data to generate reports and statistics but have no access to information that directly identifies individuals or any personal data that users provide to us.
7.2. On your first visit to the Site or the Apps you will see a pop-up to inform you that cookies are being used when you proceed with using the Site or the Apps. Although this pop-up will not usually appear on subsequent visits you may withdraw your cookie consent at any time by changing your browser or device settings.
7.3. This section explains each cookie category in more detail and how you can control their use. Please be advised that the below descriptions are indicative. They do not represent the cookies enabled on the Site. The below categorization is for the purpose of informing you about the various categories of cookies that we may or may not enable on the Site.
7.4. The length of time a cookie stays on your device depends on its type. Depending on this criterion we use two types of cookies on our Site:
7.5. We also categorize our cookies to help our customers understand the specific reason for each cookie.
a) if applicable, enable a user to log into our Site (“authentication cookies”);
b) maintain online security and protect against malicious activity and/or violation of our Terms (“security cookies”); and
c) record your preference regarding our use of cookies on your device.
These cookies remember your preferences and tailor the Site to provide enhanced features. We use this type of cookies to: make login (if applicable) faster by recognizing you if you are logged into the Site and remember relevant information as you browse from page to page to save you re-entering the same information repeatedly (e.g. language).
7.6. Cookie Preferences: You are free to change your Cookie preferences at any time. You can do this in the settings panel for your browser. Depending on which browser and device you use, you may be able to control which Cookies you allow, control which you want to block in the future, and delete Cookies. You may also delete or refuse some or all of the cookies, on our Site or Apps at any time. However, please remember that if you delete or disable some or all your cookies, some functionality or features of the Services may be disabled and your experience may be affected.
7.2. On your first visit to the Site or the Apps you will see a pop-up to inform you that cookies are being used when you proceed with using the Site or the Apps. Although this pop-up will not usually appear on subsequent visits you may withdraw your cookie consent at any time by changing your browser or device settings.
7.3. This section explains each cookie category in more detail and how you can control their use. Please be advised that the below descriptions are indicative. They do not represent the cookies enabled on the Site. The below categorization is for the purpose of informing you about the various categories of cookies that we may or may not enable on the Site.
7.4. The length of time a cookie stays on your device depends on its type. Depending on this criterion we use two types of cookies on our Site:
- Session cookies
- Persistent cookies
7.5. We also categorize our cookies to help our customers understand the specific reason for each cookie.
- Essential cookies
a) if applicable, enable a user to log into our Site (“authentication cookies”);
b) maintain online security and protect against malicious activity and/or violation of our Terms (“security cookies”); and
c) record your preference regarding our use of cookies on your device.
- Analytics cookies (tracking Site performance and giving you a better online experience)
These cookies remember your preferences and tailor the Site to provide enhanced features. We use this type of cookies to: make login (if applicable) faster by recognizing you if you are logged into the Site and remember relevant information as you browse from page to page to save you re-entering the same information repeatedly (e.g. language).
- Third-party or Advertising cookies
7.6. Cookie Preferences: You are free to change your Cookie preferences at any time. You can do this in the settings panel for your browser. Depending on which browser and device you use, you may be able to control which Cookies you allow, control which you want to block in the future, and delete Cookies. You may also delete or refuse some or all of the cookies, on our Site or Apps at any time. However, please remember that if you delete or disable some or all your cookies, some functionality or features of the Services may be disabled and your experience may be affected.
7. Our Cookies and Third-Party Analytics
8.1. In certain situations, we may be required to disclose personal data due to our legal obligations to comply with different laws and regulations. Our officers, contractors and/or employees will receive access to your Personal Information on a need-to-know basis only.
8.2. Company may share your personal Information with third parties with your consent, for the purpose of performing a contract or for other purposes defined herein. We require any company with which we may share your personal data to protect such data in a manner consistent with this Privacy Policy and to limit the use of such personal data to the performance of services for the Company or to comply with legal requirements.
8.3. To a limited extent, we may transmit personal data to the following processors:
8.3.1. Google: for analytics, advertisement and traffic services.
8.3.2. Meta: for analytics, advertisement and traffic services.
8.3.3. api:VPN: to assist us in providing the services to you and to resolve any problems you may have with the Site and the Apps.
8.3.4. Third party service providers used to process your payments (if applicable). You will be informed of specific third-party payment service providers on a separate page during the payment process on the payment page.
8.4. International transfer of personal data
8.4.1. To provide you with the best possible Services and user experience, we may have to transfer data outside of the European Economic Area (the “EEA”).
8.4.2. In such cases we ensure that we implement at least one of the following safeguards (or at least one of the following safeguards is in place) in order to maintain an equivalent level of protection in comparison to GDPR:
8.2. Company may share your personal Information with third parties with your consent, for the purpose of performing a contract or for other purposes defined herein. We require any company with which we may share your personal data to protect such data in a manner consistent with this Privacy Policy and to limit the use of such personal data to the performance of services for the Company or to comply with legal requirements.
8.3. To a limited extent, we may transmit personal data to the following processors:
8.3.1. Google: for analytics, advertisement and traffic services.
8.3.2. Meta: for analytics, advertisement and traffic services.
8.3.3. api:VPN: to assist us in providing the services to you and to resolve any problems you may have with the Site and the Apps.
8.3.4. Third party service providers used to process your payments (if applicable). You will be informed of specific third-party payment service providers on a separate page during the payment process on the payment page.
8.4. International transfer of personal data
8.4.1. To provide you with the best possible Services and user experience, we may have to transfer data outside of the European Economic Area (the “EEA”).
8.4.2. In such cases we ensure that we implement at least one of the following safeguards (or at least one of the following safeguards is in place) in order to maintain an equivalent level of protection in comparison to GDPR:
- We only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of protection for personal data.
- When using service providers located outside the EEA, we may use specific contracts approved by the European Commission. These contracts are designed to ensure that personal data receives the same level of protection as it does within the European Union.
- When using service providers located within the USA, we may transfer personal data to them if they are part of the EU-USA Data Privacy Framework. This framework requires them to provide personal data with a level of protection similar to what it receives within the EEA.
8. Sharing of the information
Users may disable or reset the mobile identifiers associated with their devices at any time. For instructions, see Apple's page on Advertising & Privacy on iOS devices and Google's page on Managing your Google Settings on your Android device.
9. Disabling or resetting mobile identifiers
During the usage of our Services, you have the following rights (subject to certain exceptions or exemptions):
- You have a right to access personal data held about you.
- You have the right to request that we rectify any personal data we hold that is inaccurate or incomplete.
- You have the right to request the deletion of your personal data. Please note that such deletion may result in us no longer being able to provide you with our Services.
- You have the right to request restriction of or object to the processing of your personal data.
- You have the right to request and receive your personal data in a commonly used format (data portability).
- You have the right to withdraw your consent on which processing is based at any time.
- You have a right to complain to your local data protection supervisory authority.
10. Your Privacy Rights
Under the “Shine the Light Act” (California Civil Code Section 1798.83), California residents may request information about any disclosure of personal data to third parties for their direct marketing purposes. We do not sell any such data to third parties for direct marketing. The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals covered by the California Consumer Privacy Act (“CCPA”):
- You have the right to know what personal data is being collected about you and how it is used and shared.
- You have the right to request the deletion of your personal data. Please note that such deletion may result in us no longer being able to provide you with our Services.
- You have the right to opt out of the sale of your personal data. However, there is no need to exercise this right as the Company does not sell any data to third parties.
- You have the right not to be discriminated against for exercising any of these rights or other rights under the CCPA.
- You have the right to withdraw your consent on which processing is based at any time.
11. Users in California
We do not offer our Services for use by minors and, therefore, we do not knowingly collect personal data from, and/or about individuals under the age of eighteen (18) or under the age of majority in the jurisdiction of residency / from which the Services are used. If you are under the age of eighteen (18), or under the age of majority in the jurisdiction where you reside or from which you use the Services, do not provide any personal data to us without the involvement of a parent or a legal guardian.
12. Use by minors
We may change our Privacy Policy from time to time, with or without notice to you, consistent with applicable privacy laws and principles. Your continued use of the Services and/or access to the Site and Apps constitutes your acceptance of our Privacy Policy. We encourage you to periodically review the most current version available to stay informed of any changes. The date of the latest version of the Privacy Policy will be displayed at the top of this page.
13. Changes to This Privacy Policy
We If you have any questions, concerns, or complaints regarding our Privacy Policy, our compliance with applicable laws, or how we handle your information or if you wish to exercise your privacy rights, please feel free to contact us through our Contact Form.
14. How to contact us