Privacy Policy - Appatomic

Appatomic Ltd (hereinafter “we”, “us” or “our”) operates the website www.vpnhub.com (hereinafter referred to as “Website”) and other applications such as the free and paid version of VPNhub, including the mobile and desktop applications of VPNhub (hereinafter “Services”) and is the controller of the information collected or provided via the Services and Website.

By accessing or using our Services and Website, you accept the terms of this Privacy Policy. If you do not agree with any part of this privacy policy or our terms, please do not access or continue to use our Services or Website or otherwise submit your personal data.

We collect, process and retain personal data to the extent it is necessary to provide users with our service. This privacy policy applies to information we collect:

• on the Services and Website,
• in e-mail or other communications between you and the Services and Website,
• through the desktop and mobile applications of VPNhub you download from the Website, Google Play, or Apple App Store, or
• when you interact with our advertising and Services on third-party websites and services, if those services or advertising include links to this privacy policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Services or Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third- party websites and we are not responsible for their privacy statements, information or other practices.

As of 03/28/2023 we have not received any National Security Letters or FISA court orders, and we have not been subject to any gag order(s) by a FISA court, or any other similar court(s) of any government. We have never placed any backdoors in our hardware or software and have not received any requests to do so. No searches or seizures of any kind have ever been performed on our assets.

Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). You do not have to give Appatomic any Personal Information to browse our Website or use our Services.

We use different methods to collect data from and about you including through:

• Direct interactions.
• Automatic data collection technologies or interactions.

Personal Information provided by users through Direct Interactions

Through Direct Interactions we may collect, use, store and transfer the following information that users choose to provide to us:

• Account Information. E-mail/username and password if you create VPNHub Premium account. No email is required to create a free version of VPNhub account. We will never require you to register or provide us any contact information to download or use our products.
• Contact data. Email address and additional Personal Information you may provide us if you contact us.
• Marketing and Communications Data. Your communication preferences and preferences in receiving marketing from us, our third parties affiliates or partners.

If you choose to purchase a subscription for VPNhub Premium account, we will not collect any Personal Information related to such payment. Payments made via Probiller, or in the Apple App Store or Google Play, will be processed by these third parties, and will be subject to such third partys’ privacy policy, and not this Privacy Policy.

Personal Information automatically collected from users through Automatic Data Collection Technologies or Interactions

We and our third party service providers may automatically collect, use, store and transfer the following information about you or your device as follows:

• When VPNHub app is launched, but before you connect to the VPN, we and our third party service providers collect device-specific information such as unique mobile ID, operating system and platform, browser type and version, network information and other technology on the devices you use to access the Website or the Services.
• When you connect to the VPNhub VPN, we collect your internet protocol (IP) address, which we pseudonymize, immediately encrypt it and store it only for the duration of your VPN session. Your IP address is deleted after you disconnect from the VPN without storing or logging it. We do not associate your IP address with your online activities and we do not store or log your IP address with your online activities.
• Usage Data includes non-personally identifiable aggregated information about how you use our Services and Website. We do not attribute any specific website visits or app usage to any specific user. We do not keep logs of your online activities and will never associate any domains, websites or applications that you use with you, your device or your email.
• Transaction Data in case of purchases, it may include details about payments to and from you and details of products and services you have purchased or received from us.
• Aggregated Data. We may also collect, use and share your data to produce and share aggregated data that do not identify you and therefore not considered as Personal Information. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Services feature, to generate statistics about our users or to calculate ad impressions clicked on.

Information Collected through Automatic Data Collection Technologies and Cookies when you visit the Website

• As you navigate through the Website, we and our third party service providers use automatic data collection technologies to collect certain information about your equipment, including information such as your device information (including device and application IDs), unique mobile ID, advertising ID, operating system and platform, browser type and version, internet service providers, mobile network names and cookie information. Such information is used only used to improve the Website, provide troubleshoot and perform analytics.
• We also use these technologies to collect information about your online activities over time and across third-party websites or other online services (“interest-based advertising”). See “Choices About How We Collect, Use and Disclose Your Personal Information” below for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
• We may use or engage others to use cookies, web beacons, clear gifs, and similar technologies to understand how users access and use our Website. In general, you can browse our Website without telling us who you are or submitting any Personal Information.
• Browser Cookies. We do not use cookies on our Website.
• Disabling Cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, be notified when you receive a new cookie, or to disable cookies. Website visitors who disable their browsers' ability to accept cookies will be able to browse the Website but certain Website features will not function.
• Analytics. We use third party analytics and advertising tools, in particular Google Analytics, Facebook Pixel and Twitter Pixel (Website only) and Firebase and AppsFlyer (for Services only). Google Analytics and Firebase are provided by Google, Inc., USA (“Google”). These tools and technologies may collect and analyze certain types of information, including IP addresses, device and software identifiers, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), and other similar information via the use of cookies or pixels. The information generated by Google Analytics or Firebase about your use of the Website or Services may be transmitted to and stored by Google (for Google Analytics and Firebase) on servers in the United States. Because we activated IP anonymization for Google Analytics or Firebase, Google will anonymize the last octet of a particular IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Facebook, Twitter, Google and AppsFlyer will use this information for the purpose of evaluating your use of the Services, compiling reports on Services activity and managing advertising content. To learn how you can opt out from this information collection by Facebook (for Facebook Pixel) by Twitter (for Twitter pixel) by Google (for both Google Analytics and Firebase) or by AppsFlyer, see “Choices About How We Collect, Use and Disclose Your Personal Information” below.

On our free version of the VPNhub users may see some generic ads that our advertising partners place such as MoPub (with Twitter as its parent organization). On our paid version VPNhub Premium, no ads will ever be served and no information will be collected by our third party advertising partners.

Please be advised that the placement of ads by Traxnet in the Services applies only for users located in Iran.

We do not track user activities outside of our Services, nor do we track the browsing activities of users who are logged into our VPNhub service. We do not share your IP address, browsing history, or any other information you choose to provide, with advertisers. We may share your general (city level) location. Advertisers may be able to collect certain information independently from you or your device when serving ads from our Services, including your device’s advertising ID, IMEI, MAC address, and wireless carrier. Advertisers may be able to access your lP address if your device is not connected to the VPNhub VPN. For more information regarding your device’s advertising ID and its options, please visit https://support.google.com/googleplay/answer/3405269 for Android or https://support.apple.com/en-us/HT202074 for iOS.

Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. Unless expressly stated otherwise, our Services does not provide any Personal Information to these third parties, however the information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Collect, Use and Disclose Your Personal Information”.

We will only use your Personal Information when applicable local law allows us to. We may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using it. Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or other communication method. We do not sell or rent Personal Information to others, we do not log your browsing data and we delete your IP address when you disconnect from VPNhub’s VPN.

In general, we use information that we collect about you or that you provide to us through our Services and Website, including Personal Information, to create new accounts (VPNhub Premium), identify and communicate with current subscribers, offer troubleshooting, customer support and notices to registered users about their accounts, including expiration and renewal notices, notices about changes to our Services, Website, changes to the our Terms and Conditions and policies or any products or services we offer or provide through them. We may also use Personal Information for the following reasons:

• To verify your identity when you login to the Services;
• To administer, maintain and improve our Services;
• Provision of services: to present our Services and their contents to you, including any interactive features on the Services, and to provide you with information, products or services that you request from us;
• Customization of content: to perform research and analysis about your use of, or interest in, our Services and Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other sites;
• Advertising: To communicate with you and send you promotional information that may interest you about products, services, and offers made available by us, our affiliates or our marketing partners if you have consented to receive such information from us (For more information, see “Choices About How We Collect, Use and Disclose Your Personal Information”); and
• To analyze usage and trends on our Services and to better understand how users use the Services.
• Business purposes such as audits.
• Functionality and security: to diagnose or fix technology problems, and detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
• Compliance: to enforce our terms and conditions and to comply with legal and regulatory obligations;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this privacy policy.
• Service Providers. With third party service providers who provide services on our behalf such as processing payments (Probiller, Google Play and Apple App Store). Our service providers receive only the information necessary to perform their designated functions, and are not permitted to use or disclose this information or your Personal Information for their own marketing or other purposes;



• Provider	Service	About
  Probiller	Payment Processor	Learn more
  Google Play	Payment Processor	Learn more
  Apple App Store	Payment Processor	Learn more



• Aggregate, Anonymous or De-Identified Information. Sharing aggregate or non- personally identifiable information with non-affiliated third parties for advertising, marketing or research purposes. We do not share your personal information with any third parties for their own marketing, advertising or research purposes.

We use appropriate security measures (including physical, electronic and procedural measures) that are consistent with industry standards to protect your Personal Information we collect and maintain about you from loss, theft, misuse or unauthorized access or disclosure or destruction such as encryption, access controls, passwords or technical or physical security measures and safeguards. All employees and service providers are up-to- date on our security and privacy practices. Access to user Personal Information is restricted to those who need to know such information to perform their job functions.

Despite our efforts, no data security methods guarantee 100% protection. We do not promise and cannot guarantee that your Personal Information can never be viewed and/or used by others. You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Services.

We do not disclose your Personal Information except in the limited circumstances described here:

• Members of corporate group. To members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) who operate services that help us with: customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
• Service providers. To our authorized service providers that perform services on our behalf such as payment processing who may have access to Personal Information necessary to perform their functions but are not permitted to share or use such information for other purposes.
• Legal successors. To a buyer or successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Services and Website users is among the assets transferred. Should such sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses it in a manner that is consistent with this privacy policy.

We do not require you to provide us with any contact information in order to download or use our Services, we do not log or store your IP address after you disconnect from the VPN, and we do not keep logs of your online activities. If you use VPNhub Premium, no Personal Information is shared with third party advertisers.

We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Services, Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose aggregated information about our users, and information that does not identify any individual. We may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope our users will find of interest.

Appatomic's servers are based in the United States so your Personal Information will be processed by Appatomic in the United States, where data protection laws may be different from other parts of the world. Whenever in the course of sharing information we transfer Personal Information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this privacy policy and as permitted by applicable laws on data protection.

By using the Services you consent to the transfer of information that we collect about you, including Personal Information, to any country, including the United States, in which we, members of our corporate group (as defined above) or our service providers are located.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. The retention period that is necessary for compliance and legal enforcement purposes varies and depends on the nature of our legal obligations and claims in the individual case.

Where we no longer need to process your Personal Information for the purposes set out in this Privacy Policy, we will delete your Personal Information. Where permissible, we will also delete your Personal Information upon your request.

We strive to provide you with choices regarding the Personal Information you provide to us.

• You can choose not to provide us with certain Personal Information, but that may result in you being unable to use our Services or certain features of them because such information may be required in order to register as a member (email is required to create a VPNhub Premium account); purchase products or services; contact us (email is required when contacting customer support); or initiate other transactions on our Services.
• You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Website may become inaccessible or not function properly.
• You may opt out of Firebase cookie or Google Analytics by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page.
• Opt-Out from Third-Party Pixels:



• Source	Listing	About	Opt-Out
  Facebook	staticxx.facebook.com www.facebook.com	Learn more	Disable
  Google Analytics	ssl- googleanalytics.com	Learn more	Disable
  Twitter	platform.twitter.com branalytics.twitter.com t.co	Learn more	Disable



• AppsFlyer: You can opt-out from being tracked by AppsFlyer by emailing a request to privacy@appsflyer.com or by completing the ApplsFlyer Opt-Out form.
• MoPub: You may opt-out from MoPub by visiting the MoPub Opt-Out Information Page.
• When you create an account on our Services, you may be given a choice as to whether you want to receive email messages, newsletters or both about product updates, improvements, special offers, or containing special distributions of content. If you no longer want to receive commercial or promotional emails or newsletters from us, you will need to avail yourself of the unsubscribe mechanism set out in the applicable communication. It may take up to seven days for us to process an opt-out request. Please note that we may send you other types of transactional and relationship e-mail communications, such as administrative notices without offering you the opportunity to opt out of receiving them.
• You may delete your account with us at any time. If you delete your account, your Personal Information and all account-related information will no longer be accessible by you and will not be saved. After deleting your account, if you choose to have an account with us in the future, you will have to sign up for a new account.

Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose, including the right:

• to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
• to rectify inaccurate Personal Information concerning you (right to data rectification);
• to erase your Personal Information (right to erasure, “right to be forgotten”);
• to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability);
• to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
• in some cases, to restrict our use of your Personal Information (right to restriction of processing).

If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. In case of a withdrawal of your consent you may no longer able to use several functionalities of our Services.

You may send us an e-mail at support@appatomic.net to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g. e-mail address). It is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.

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 child under 16 has provided Personal Information, we will take steps to delete such information.

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at https://www.appatomic.net/privacypolicy, so you are aware of any changes, as they are binding on you and refresh the page when doing so.

If we change anything in our privacy policy, the date of change will be reflected in the “last modified date”. If we make material changes to this privacy policy, we may choose to notify you through the Services or by sending you an email or other communication. By continuing using the Services and Website subsequent to us making available an amended version of our privacy policy in a way that you can easily take notice of it, you thereby consent to such amendment.

We regularly review our compliance with this privacy policy. Please feel free to direct any questions or concerns regarding this privacy policy or our treatment of Personal Information by contacting us through the Website or the Services at support@appatomic.net. When we receive a formal written complaint, it is our policy to contact the complaining party regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of Personal Information that cannot be resolved by an individual and us.

This privacy policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Services.

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy. The laws of Cyprus shall, to the extent applicable, govern this privacy policy.

If you have any questions about this privacy policy or our information-handling practices, please contact us at support@appatomic.net.