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Privacy Policy

Last updated: May 20, 2024

This document ("Privacy Policy") explains the privacy rules applicable to personal data and other information collected or submitted when you access, install, or use CicadaVPN services and websites, regardless of the device you use (computer, mobile phone, tablet, etc.).

The data controller of your personal data, as described in this Privacy Policy, is CicadaVPN LTD. (address: [insert address]; email: privacy@cicadavpn.com) ("CicadaVPN", "we", "us", or "our").

The capitalized words used in this Privacy Policy as definitions are defined here or in our General Terms.

By visiting our websites, submitting your personal data to us, and accessing, installing, and/or using our services, you confirm that you have read this Privacy Policy and agree to be bound by it. If you do not agree with this Privacy Policy or any provisions hereof, please do not use our services and websites.

1. PROCESSING OF YOUR PERSONAL DATA​

CicadaVPN processes personal data to a limited scope to provide services, process payments, and enable the functioning of our websites and mobile applications. We may process the following categories of personal data:

Information for Creating Your Account​

  • Email Address: Required for registration, account creation, password recovery, and service usage.

Subscription Information​

  • Subscription Data: Includes your email address, chosen subscription plan, subscription term, ID, frequency, status, auto-renewal status, and features enabled/disabled (e.g., multi-factor authentication).
  • Payment Data: Necessary for payment collection, processed by our payment partners. We may also process some billing information ourselves in specific cases.
  • Country Details: Processed for VAT calculation purposes.
  • Payment Fraud Prevention: Personal data may be verified by us and/or our payment partners to prevent fraudulent payments.
  • Information Concerning Zero Authorization for Billing: Confirms the validity of your payment method without collecting personally identifiable information.
  • Information Related to A/B Price Testing: Used to optimize pricing strategies, which may include data collection related to your behavior, preferences, or responses.

Communication Data​

  • Email Address: Used to send updates, respond to inquiries, and send offers or surveys (opt-out available).
  • Customer Support Inquiries: Includes information necessary to resolve queries, such as payment verification details, country, OS information, and local application logs.
  • Communication Optimization Data: Used to optimize email campaigns and push notifications.
  • Chatbot and Live Chat Widget: May collect device information and IP address to assist support and optimize service.

Information Collected on Our Applications and Websites​

  • Service Usage: Information about the specific CicadaVPN services and features you use.
  • Access Logs: Includes IP address, browser type, and operating system for security and service performance.
  • Cookies: Used to improve website functionality, analyze usage, and for advertising. More details are provided in our Cookie Policy.

Referrals Data​

  • Information for Participating in Referral Programs: Requires the referrer to provide personal data about themselves and the referred party. It is the referrer's responsibility to abide by applicable privacy laws.

Promotional Games Data​

  • Information for Participating in Promotional Games: Includes full name, email address, and phone number. Participation is voluntary, and data provided may be shared with third parties involved in organizing such games.

Social Networks Data​

  • Account Data: Used for managing and administering our profiles on social networks. This includes data voluntarily provided by you, such as your full name, profile name, pictures, and public comments.

2. GROUNDS FOR PROCESSING OF PERSONAL DATA​

Your personal data is processed:

  • Contractual Necessity: To provide access to our services, process transactions, and ensure secure and reliable performance.
  • Legal Obligation: For record-keeping, tax purposes, and compliance with applicable laws.
  • Consent: For sending marketing communication and managing participation in contests or promotions. You can withdraw your consent at any time.
  • Legitimate Interests: For business communication, fraud prevention, security issues, and service improvement.

3. SHARING YOUR PERSONAL DATA​

We do not share your personal data with third parties except as described in this Privacy Policy.

Service Providers​

We use third-party service providers for various operations, such as payment processing, email automation, diagnostics, and analytics.

CicadaVPN Partners​

Our partners, such as distributors and resellers, may process your personal data as independent data controllers. Procedures established by them will apply to such relationships.

Business Transfers​

In the event of a business sale, merger, acquisition, or similar event, we may share your personal data with the new entity.

Protection of Our Rights​

We may disclose personal data to establish or exercise our legal rights or defend against legal claims.

Requests for Data​

We carefully review each request for user data to ensure it complies with applicable laws.

Cross-Border Transfers of Personal Data​

Your personal data may be transferred and processed in countries where CicadaVPN operates. We ensure suitable safeguards are in place for such transfers.

You have the following rights concerning your personal data:

  • Delete: Request the erasure of your personal data.
  • Access: Know and access the personal data we have collected about you.
  • Rectify: Correct inaccurate/incomplete personal data.
  • Object: Object to processing based on legitimate interests.
  • Portability: Request a copy of your personal data or have it transferred to another controller.
  • Restrict: Restrict the processing of your personal data.
  • Withdraw Consent: Withdraw your consent where applicable.

To exercise your rights, contact us at privacy@cicadavpn.com.

5. DATA SECURITY​

We maintain strict controls over the personal data we collect, implementing physical, technical, and organizational measures to protect your information. These include:

  • Physical Measures: Controlled access to facilities and secure storage of devices containing personal data.
  • Technical Measures: Layered defense with firewalls, anti-malware protection, and encryption of data.
  • Organizational Measures: Adoption of security policies, regular audits, and ongoing employee training on data protection.

Despite these measures, no technology is completely bulletproof. By using our services, you acknowledge that we cannot guarantee 100% security.

6. DATA RETENTION AND DELETION​

CicadaVPN will retain your personal data only as long as necessary to provide services or fulfill legal obligations. Specific retention periods include:

  • Billing Information: Retained for 10 years from the last transaction.
  • Marketing Communication: Retained for 1 year after the end of your subscription or until you opt out.

When we no longer have a legal basis to retain your personal data, it will be securely disposed of or anonymized.

7. COUNTRY-SPECIFIC PROVISIONS​

For Users in the European Economic Area (EEA)​

Residents of EEA countries can exercise their GDPR rights by contacting us at privacy@cicadavpn.com.

For Users in California​

California residents can exercise their rights under the CCPA by contacting us at privacy@cicadavpn.com. CicadaVPN does not sell, share, lease, or rent your personal information.

8. CONTACT US​

If you have any questions, requests, concerns, or complaints about this Privacy Policy or our personal data processing practices, please contact us via privacy@cicadavpn.com or by writing to us at:

CicadaVPN LTD.
[Insert Address Here]

9. CHILDREN’S DATA​

CicadaVPN does not knowingly collect or solicit personal data from anyone under the age of 18. If you are under 18, please do not attempt to send any personal data to us. If we become aware of collecting personal data from a child under 18, we will delete it promptly.

10. OTHER TERMS​

Limitation of Liability​

CicadaVPN employs various security measures to protect your data, but you are responsible for exercising caution when using our services. We are not liable for unlawful activities, willful misconduct, or circumstances beyond our control.

Our websites may include links to other sites whose privacy practices differ from ours. We encourage you to read the privacy policies of any website you visit.

Prevailing Language​

The English language version of this Privacy Policy is the original, governing instrument. In case of conflict between the English version and any translation, the English version shall prevail.

Updates to the Privacy Policy​

We may amend this Privacy Policy from time to time. If changes materially affect the processing of your personal data, we will notify you in advance. Your continued use of our services after the amendments signifies acceptance.

Made with ❤️ by Infinum team.