Privacy policy

1. General information.

1.1. This document, referred to as the Privacy Policy ("Policy"), outlines the privacy practices of Umbrella VPN, a limited liability company operating under Romanian Law (referred to as "Umbrella" or "Company" or "Umbrella VPN"). It applies to all individuals ("users" or "you"), whether Free Users or Commercial Users, utilizing the products or services ("Products or Services") provided through the company's Websites, as detailed in our Terms and Conditions.

1.2. It's essential to understand this Privacy Policy within the context of the Terms and Conditions. Together, they constitute a legally binding agreement between you and Umbrella VPN, so please review them attentively.

1.3. Safeguarding your privacy is paramount to us. Hence, we handle your personal data with utmost care, adhering to the principles outlined in the General Data Protection Regulation (GDPR) and Romanian data protection laws, particularly Law no. 363/2018 on personal data processing and free movement of such data (the "Data Protection Law"), collectively known as the "Data Protection Legislation."

1.4. According to Data Protection Legislation, personal data refers to any information concerning an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, particularly through an identification number or specific factors related to their physical, psychological, mental, economic, cultural, or social identity.

1.5. Please acknowledge this Privacy Policy before engaging with our Products or Services or accessing our Websites.

1.6. This Policy extends to all Products or Services offered via our Websites. However, it does not encompass any third-party website, product, or service, even if linked to (or from) our Websites. Prior to sharing any information, it's advisable to review the privacy practices of any third-party entity. By utilizing our Products, Services, or Websites, you agree to adhere to the practices outlined in this Policy. If you disagree with this Policy, kindly refrain from visiting or utilizing our Products, Services, or Websites. Continued usage of our Products, Services, or Websites signifies your acceptance of this Policy.

2. Data Collection

2.1. Information Gathering Regarding Your Account ("Personal Data")

2.1.1. Upon utilizing our Websites by registering and/or establishing a new account, purchasing our Products or Services, submitting and/or sharing content, or providing feedback, you may be prompted to furnish personal details such as your name, address, email address, username, payment information, personal identification number, and other identifying information voluntarily submitted during the ordering or subscribing process for our Products or Services, as well as when completing any contact forms on the Websites.

2.1.2. Kindly note that when voluntarily disclosing your Personal Data (including name, age, date of birth, personal identification number, mailing/email address) in discussion forums or other public areas on the Websites, such information, along with any details revealed in your communication, may be collected and utilized by third parties, potentially resulting in unsolicited messages (e.g., spam). These activities are beyond our control, and this Privacy Policy does not extend to such information.

2.2. Aggregated Information ("Non-personal Data")

2.1.3. Additionally, we gather and/or receive and store specific non-personal information ("Non-personal Data") whenever you interact with us. This data may encompass a website’s Uniform Resource Locator (“URL”) pointing to the site you arrived from, your browser type, and your Internet Protocol (“IP”) address. This process primarily ensures the support and security of our Websites. Such information is crucial for combating DDoS attacks, scans, and similar hacking attempts. We utilize this data to enhance our site's design, diagnose server issues, and manage our Websites. You can request the deletion of your data by submitting a valid deletion request (refer to Section 7 for further details). Please be aware that deleting your Personal Data will result in the inability to use our Products, Services, or Websites.

2.1.4. Non-personal Data is not linked to your Personal Information and thus does not enable the identification of individual persons.

3. Personal Data Collection Methods

3.1. Our Websites feature registration forms (e.g., during the payment process by providing credit card or other payment details when ordering and purchasing Products or Services, or during customer support and review) that, at your discretion, may request certain information such as email address and others as previously detailed. For instance, we utilize this data to establish an account, deliver the service, send news updates and promotional materials about our products or from selected partners, and when you participate in sweepstakes or contests sponsored by us or our partners, sign up for special offers from specific third parties, or correspond with us via email, phone, or mail.

3.2. We do not share this information with third parties, except as specified below, and only with individuals or entities associated with our Products, Services, or Websites.

3.3. To maintain high service quality and a superior customer support experience, Umbrella VPN engages certain third parties, such as advertising partners (“Advertising Partners”), to collect and process specific aggregate data. For instance, we may utilize your IP address to diagnose server, software, or hardware issues, and/or to gather demographic data. Our Advertising Partners may furnish us with aggregate reports informing us of the number of advertisements displayed and clicked on our Websites.

4. Purpose of Personal Data Collection and Processing

4.1. Umbrella always processes personal data lawfully and fairly. We solely process personal data for specific, predefined purposes consistent with applicable laws and pertinent to our business.

4.2. We collect Personal Data for the following purposes:

- Fulfillment of contractual obligations, including providing users with requested Products or Services, managing subscriptions, and processing payments associated with our Products, Services, or Websites.

- Enhancement of user experience, our products, and services, encompassing features, functionalities, and interfaces.

- Provision of technical support for products and services, improving product and service quality, proper administration of our Products, Services, or Websites.

- Execution of contracts between you and us and/or undertaking steps, at your request, to enter into such contracts.

- Scientific research, fraud detection/prevention, and enhancement of our Products, Services, or Websites.

- Notification of new services or changes to existing Products, Services, or Websites, communication regarding your requests, and transmission of technical or service-related communications.

- Enforcement of Terms and Conditions.

5. Sharing of Personal Data

5.1. We do NOT share, sell, rent, or trade your Personal Data with third parties other than as elucidated within this Privacy Policy, maintaining consistent protection standards and only to the extent reasonably necessary for the purposes outlined in this Policy.

5.2. Certain Products or Services may be provided through contractual arrangements with affiliates, service providers, partners, and other third parties (“Service Partners”). We and our Advertising Partners or Service Partners may need to utilize some personal information to facilitate tasks between our respective websites or deliver Products or Services to you. For example, we may need to share your credit card information with the card-issuing bank to confirm payment for Products or Services purchased on the Websites, share your address information with delivery services for ordered products, or provide order information to third parties assisting in customer service. We advocate for robust privacy policies among our Service Partners.

5.3. Our Websites may contain links to external websites, mobile applications, products, or services not owned or controlled by Umbrella VPN and subject to specific terms and conditions. Third parties may collect personal information from you, and Umbrella VPN bears no responsibility for their privacy practices or content. We advise reviewing the terms, conditions, and privacy policies of each third-party service provider engaged in connection with our Products, Services, or Websites.

5.4. We may collect and potentially share your Personal Data to enforce Terms and Conditions, prevent crimes or violations of our Terms and Conditions, or aid in resolving committed transgressions.

5.5. Additionally, we reserve the right to disclose your Personal Data as required by law or when we deem disclosure necessary to safeguard our rights or comply with legal processes, including judicial proceedings, court orders, or legal mandates served on our Products, Services, or Websites. We fully cooperate with law enforcement agencies to identify individuals utilizing our Products, Services, or Websites for unlawful activities, and we reserve the right to report unlawful activities to law enforcement agencies in good faith.

5.6. Finally, we may share Non-Personal data associated with the use of our Products, Services, or Websites with third-party suppliers for optimization, customer analytics, and fraud prevention purposes, evaluating Websites usage, compiling reports on Websites activity, and offering other internet-related services, all in accordance with their applicable privacy policies.

6. Security Measures for Your Personal Data

6.1. We adhere to widely accepted industry standards to safeguard the Personal Data you provide to us, both during transmission and upon receipt. We have instituted top-tier physical, procedural, and technical security protocols concerning our offices and data storage facilities to prevent any loss, misuse, or unauthorized access, disclosure, or alteration of your Personal Data. These measures include:

- Diligent efforts to ensure the reliability, accuracy, completeness, and currency of the data we collect.

- Encryption of all Personal Data during transmission to prevent unauthorized access.

- Utilization of Personal Data solely for the purposes for which it was collected or to comply with applicable legal or ethical reporting or document retention requirements.

- Restricting access to Personal Data to specific employees, contractors, and agents with a legitimate need to access your information. For example, members of our technical support team may have limited access to your account to assist in troubleshooting website issues. These individuals are bound by confidentiality obligations and may face disciplinary action, including termination and legal prosecution, for failing to meet these obligations.

- Implementation of various physical, electronic, and procedural safeguards to protect Personal Data, including industry-standard encryption on our servers and datacenters, as well as high-level password protection.

- Provision of access to your Personal Data through a password and unique customer ID chosen by you. Your password is encrypted, and we advise against disclosing it to anyone.

- Handling of credit card transactions and order fulfillment by reputable third-party banking institutions and processing agents (e.g., PayPal, Venmo, Zelle) who receive necessary information solely for verifying and authorizing your payment and processing and shipping your order.

6.2. However, it's important to note that while we strive to employ commercially acceptable means to safeguard your Personal Data, no method of transmission over the Internet or electronic storage can guarantee 100% security. Therefore, we prioritize minimal data collection to mitigate risks. If you suspect that the security of your interaction with our Products, Services, or Websites has been compromised, please contact us immediately.

6.3. Should you believe that your privacy has been compromised contrary to our Policy or encounter misuse of our Products, Services, or Websites, please reach out to us directly at support@umbrellavpn.net. Additionally, in the event of a data breach posing a risk to your Personal Data, we will promptly notify you through your account or email, if feasible.

7. Your Privacy Rights

7.1. As data subjects, you are afforded certain rights under Data Protection Legislation, including:

- Access to personal data held about you.

- Rectification of any inaccurate or incomplete personal data we hold.

- Deletion of your personal data, understanding that it may affect our ability to provide you with our Products or Services.

- Restriction of or objection to the processing of your personal data.

- Receipt of your personal data in a commonly used format (data portability).

- Withdrawal of consent for processing based on your consent.

- Right to lodge a complaint with your local data protection supervisory authority.

- Authorization for a third party to submit requests on your behalf, contingent upon written authorization signed by you.

7.2. We are committed to facilitating the exercise of your relevant rights and offer options for choices and controls regarding the treatment of your Personal Data. Depending on your relationship with us, these options may include accessing, correcting, updating, or deleting the information associated with you. If you wish to opt out of data collection or cannot exercise your rights through your account, please contact us at: support@umbrellavpn.net.

7.3. Should you make such a request, note that we may require certain information to verify your identity and locate your data, and the process of locating and deleting data may require reasonable time and effort. Additionally, data privacy laws in your jurisdiction may afford you different or additional rights related to the data we collect from you.

8. Policy Revisions

8.1. Our Privacy Policy may undergo periodic updates, either with or without prior notice to you, in accordance with relevant privacy laws and principles. Should we decide to modify our Privacy Policy, such changes and updates will take effect immediately upon publication of the revised version. Therefore, we encourage you to routinely review this Privacy Policy to stay informed about how your data is collected and utilized by the Company, as well as your associated rights.

8.2. By continuing to use the Products, Services, or Websites subsequent to the publication of these revisions, you acknowledge and consent to the updated Privacy Policy. Your ongoing use implies your acceptance of the terms outlined in the amended policy.

9. How to Reach Us

9.1. If you have inquiries, concerns, or grievances regarding our Privacy Policy, our adherence to applicable laws, our handling of your information, or if you wish to exercise your privacy rights, please don't hesitate to contact us:

- Via email: Addressed to Customer Service at support@umbrellavpn.net