NETTIKER PRIVACY POLICY

GENERAL INFORMATION

This document (“Privacy Policy”) explains in detail the privacy practices that apply to personal data and other information collected or provided by you when you access, install or use the Nettiker Services and Websites, regardless of device (computer, mobile phone, tablet , etc.) that you use to interact with our services.

The current Privacy Policy remains in effect until replaced by a new policy. We reserve the right to update the Privacy Policy at our sole discretion. You will be notified of changes to this policy by a letter to your e-mail address specified when ordering our Services (registration in the system). Also, the current version of the policy will have the mark of the last update, which is shown on the Nettiker Website at the top of the current page. Your continued use of the Website and our Services will constitute your acknowledgment, full understanding, and acceptance of the terms of the current version of the Privacy Policy.

The functional structure of our systems has been designed in such a way that our company can completely refuse to collect logs of your Internet activity, including the registration of your browsing history, the contents of all this data, as well as incoming / outgoing DNS requests. We also do not store connection logs on our servers, i.e. logs identifying your personal IP address, your originating VPN IP address, connection timestamp and session duration.

Access to user information is limited to personnel who need such access to perform their job functions. A unilateral non-disclosure agreement (NDA) is mandatory for each employee of our company, which restricts the ability to use and distribute the company's confidential information.

Nettiker servers are hosted in data centers with the most stringent security rules. None of these centers require our company to collect or store any traffic data or personal information related to your use of the Nettiker VPN Services. In case of receiving a request from the data center with the requirement to register or fix the personal data of our customers, we will immediately unilaterally terminate the contractual obligations with this data center and find alternative options.

It is important to understand that no security systems that currently exist in the world can 100% guarantee data protection. Any information collected from you through the Website or our Services is provided at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please let us know at support@nettiker.com or law@nettiker.com.

Based on the information above, it follows that we are physically unable to provide the competent authorities or third parties with any detailed information about you and your activity due to the complete absence of such information. The exception is your personal email address, specified by you when registering in the billing system at https://my.nettiker.com/ . Registration of this address in the system serves to identify you as a user. Details of the intended use of the e-mail address provided by you will be described in this document below in the text.

PROCESSING OF PERSONAL DATA

Nettiker's processing of personal data is limited and is required to: provide the Services, process payments for the Services, and operate our Websites and mobile applications. We may process the following categories of personal data:

Information associated with your account

This information is collected for the purpose of administering your account and subscribing to Nettiker services and includes your name, email address and billing information that you provide on our order page when subscribing to the Services using your User Account at https:// my.nettiker.com.

The storage of data required for registration and administration in the system, specified above, is carried out on systems and servers owned by the company or rented by Nettiker and its subsidiaries.

The e-mail address you provide is also used to send important notifications regarding your account, the operation of services, transactional information, marketing information (discounts, promotions), interaction with Nettiker service support services, as well as resetting your personal password if it is lost.

Under no circumstances will we send spam emails! You can individually set up the refusal to receive marketing or informational messages in the User's Cabinet on the website https://my.nettiker.com/ during or after registration in the system.

Social media data

When registering in the User Account (https://my.nettiker.com/ ), using simplified form through social networks (Twitter, Facebook) or the Gmail mail service, you provide information that you opened voluntarily for public access in the security settings of these services. These may be the full name, the name of the profile on the social network, the image set as the avatar.

To manage and administer our corporate social media accounts ("Facebook", "Instagram", "Twitter", "LinkedIn", "YouTube"), we may collect and process your personal data (full name, social media profile name, images and/or public comments) that you have provided voluntarily.

Payment related information (payment transactions)

Payment data. This information is necessary to collect and process payments for the Services we provide. Our payment processing partners (payment services, gateways) such as Stripe, PayPal process basic payment information for making payments and refund requests (e.g. date of purchase, payer IP address, zip code, full name of credit card holder and information about credit card). On our part, only some parts of the payment information are processed, such as the date of the transaction (payment), part of the credit card number (last 4 digits) used for payment and its validity period, as well as in the case of connecting regular payments or when you voluntarily provide your payment details directly to us through the User's Cabinet.

The minimum amount of personal information is provided only when making payments in cryptocurrency.

When making some forms of payment, the User Account ( https://my.nettiker.com ) may redirect you to the website of a third-party payment service (namely, PayPal, BitPay) to successfully process the payment (transaction). To understand what personal information these payment services collect and store, please review the terms and privacy policy of the respective service.

Stripe Privacy Policy - https://stripe.com/en-fr/privacy

PayPal Privacy Policy - https://www.paypal.com/en/webapps/mpp/ua/privacy-full

BitPay Privacy Policy - https://bitpay.com/about/privacy

Information about the user's country. When making a purchase of the Service, we process information about the country of the user from which the purchase is made. This information is necessary for the purpose of calculating and charging VAT (Value Added Tax).

Information to prevent payment fraud. In order to prevent fraudulent payments for the Services, your personal data (email address) is verified by partner anti-fraud services when making payments. A payment transaction that is considered high risk may be rejected by us unilaterally.

Information when communicating with the user

E-mail address. We use your email address only to transfer transactional information, marketing information (discounts, promotions), send duplicate ticket messages when interacting with support services, to inform about important system updates, and also to inform about suspicious actions with your account.

Chatbot. When registering, paying for the Services and managing a personal account using our chatbot in Telegram, information about your full name, which you voluntarily provided when registering on the Telegram instant messaging service, may be additionally disclosed. If this information is closed for public access in the security settings of the Telegram service, this information will not be disclosed. Subscribing to a Telegram chatbot can be done in two ways: directly through the Telegram instant messaging service and using a widget on our company's website.

Live chat widget on the Website page. When you communicate with us using the live chat widget, in addition to processing your contact information listed above in this document, we also process information about your device (type of operating system and browser) and the current IP address of your device. This information is necessary to determine the country of the user, prevent abuse of communication, and verify that the user has an up-to-date subscription to our Services.

In general, this information will help our support team to process incoming requests from customers as quickly as possible.

The platform on which the live chat widget operates uses modern security methods and HTTPS encryption when transmitting data.

Information collected by our Website
( https://nettiker.com ) and User Account ( https://my.nettiker.com )

Access logs. The user and service management system, referred to in the document as the “User Cabinet”, collects information about the accesses made to the service platform (such as the IP address from which the login was made, the time of the login, the changes made to the contact information). This information is essential only to combat DDoS attacks, various types of scanning and similar attempts to hack the company's service.

Cookie. Cookies are small text or graphic files that are placed on your personal device when you visit our Website and User Account. Some cookies are necessary for the smooth operation of our sites, as well as simplified authorization of our service customers; others store information about your preferences and allow us to personalize the Website and User Area to suit your needs. We also use affiliate cookies to identify customers referred by our partners to our Website so that we can give referral partners their commission.

If you do not want to accept cookies from our Website and User Cabinet, you can change your browser settings and cookies will no longer be processed by your browser. All popular browsers (Chrome, Edge, Firefox, Opera and Safari) allow you to flexibly change your cookie settings. You can find information about disabling cookies in the main browsers under "How to find information about controlling cookies" on the Information Commissioners' website https://ico.org.uk/for-the-public/online/cookies.

Third Party Resources (Sites) - The Nettiker website may contain links to external (third party) websites that are not part of the Nettiker domain. Nettiker is not responsible for the privacy practices or the content of such external websites.

Referral partner data

Information for participation in referral programs. Participation in referral programs operated by Nettiker requires referral partners to provide personal information of the following nature: full name, email address, phone number, so that our company representatives can personally contact the partner regarding participation in referral programs and / or provision of rewards.

The Referral Partner must comply with applicable privacy laws when disclosing personal data of third parties to Nettiker, including informing third parties that they are providing their personal data through Nettiker referral partners and how it will be used and processed. Invited parties may unsubscribe at any time.

Use of your personal data by third party services

We do not transfer your personal data to third parties, except as described in this paragraph of the Privacy Policy.

Service providers. We use the services of third party service providers for the processing of payments, website and application diagnostics, analytics and market research. These services allow us to optimize the business processes of our company and maximize the quality and speed of service to our customers. As a result of cooperation with third parties, the providers of these services may process personal data on their side.

Main long-term service providers:

Payment processing, payment gateways - Stripe (Stripe Inc.), PayPal (PayPal Inc.), BitPay (BitPay Inc.)

Online Chat (Live Chat) and Help Desk Platform - SendPulse (SendPulse Inc.), HelpCrunch (HelpCrunch Inc.)

Marketing & Analytics - Google Analytics (Google Inc.)

Technical Partners, Applications - VPNresellers (SpiderSilk Ltd.)

Storage and deletion of data

Nettiker will only retain your personal data for as long as it is necessary to provide you with the Services, or for as long as we have another legal basis to do so, but no longer than is permitted or required by law. Some of the data storage conditions are listed below:

  • Payment information and payment details of customers are stored by Nettiker for 10 years from the date of the last payment operation (transaction).
  • Nettiker will use your email for marketing communications for 1 year after your subscription ends.

When we no longer have a legal basis to store your personal data, it will be securely deleted.

COUNTRY-SPECIFIC PROVISIONS

Nettiker is committed to providing maximum user privacy anywhere in the world, and our practices reflect this by minimizing data collection and ensuring that users have full control over their personal information.

Users in the European Economic Area (“EEA”), the European Union (“EU”). The General Data Protection Regulation (GDPR) of the European Union (EU) requires a comprehensive statement of the methods and purposes of data processing relating to all users in the European Union.

In accordance with the requirements of the GDPR, we collect and process the data specified in this Privacy Policy for certain purposes, depending on the circumstances:

  • In order to fulfill our contractual obligations to users:
    1. Providing users with the Services they have requested.
    2. User subscription management and payment processing.
    3. Providing technical, financial and legal support to clients.
  • In order to pursue legitimate interests related to the functioning of our company:
    1. Improving the quality, reliability and efficiency of our services, websites and applications.
    2. Communication with customers to provide information and receive feedback about our services and applications.
  • With the express consent of users, which they can revoke at any time.

You can exercise your rights under the GDPR to access, transfer, correct, delete or object to the processing of your personal data by contacting us at law@nettiker.com.

Users in California. If you are a California resident, you can exercise your rights under the California Consumer Privacy Act ("CCPA") by contacting us at law@nettiker.com. Please note that as defined in the CCPA, Nettiker does not sell, transfer or rent your personal information.

CONSENT AND AGE LIMITS

By using our Website, User Account, Applications, Software or Services, you voluntarily consent to the processing of your personal data as described in our Terms of Service and Privacy Policy.

Our Services are intended only for individuals over the age of 18. Nettiker does not knowingly collect or solicit personal information from anyone under the age of 18. If you believe that your child has provided us with personal information, please notify us immediately at law@nettiker.com or by any means of communication convenient for you, and we will delete this information immediately.

LIMITATION OF LIABILITY

To ensure maximum security of users' personal data, Nettiker applies various technical and organizational security measures. However, it is your responsibility to use the Services and Websites with care and discretion. You will be personally liable if your use of the Services and Websites violates the privacy of third parties or any other rights or any applicable laws. Under no circumstances shall Nettiker be liable for the consequences of your illegal, willful or negligent actions, or for any circumstances that could not be reasonably controlled or foreseen.

CONTACT US

If you have questions, requests, concerns or complaints about this Privacy Policy or our personal data practices, please contact us at law@nettiker.com or write to us at the following address:

Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152. NETTIKER OÜ