Introduction

EVYN DATA OÜ (hereinafter “we”, “us” or “our”) operates the website www.evyndata.com (hereinafter referred to as “Website”) and other applications such as the free and paid version of EGO VPN, including the mobile and desktop applications of EGO VPN (hereinafter “Services”) and is the controller of the information collected or provided via the Services and Website.

In your utilization of our Services and Website, you accept the terms of this Privacy Policy.

Should you disagree with our terms of service or the privacy policy, you should immediately discontinue use of the Services or Website and refrain from submitting personal data.

In order to deliver our service to users, it is necessary that we collect, process and keep certain elements of personal data. We may collect information, to which this policy pertains, from a variety of sources, including:

• *via our Services and Website,
• *via any communication made between you and the Services and Website, for example email
• *via the EGO VPN desktop and mobile applications which you download and install on your device(s)
• *during interactions with our service or adverts for our service on third party websites or third party services, where those include links to this policy document

This policy is not relevant to any data collected by:

• *ourselves, whether that be offline or through alternative means, including via any other website operated by us or any third party (including 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. Interaction with such content through clicking links or establishing and authorising connections may result in other parties collecting or sharing your personal information. The privacy policies or data protection practices of any such third parties are entirely outwith our control and accountability.

What data we collect and how we collect it

Personal data, or personal information, is defined as any item or items of information about an individual by which that person can be identified (“Personal Information”). You do not have to supply EVYN DATA OÜ with any Personal Information in order to navigate and read our Website or in order to use our Services.

We may collect your personal information via a number of different means, including:

• *Direct interactions with you in person or via electronic or voice communication
• *Automated information collection technology or interactions.

Direct Interactions – what personal information is collected?

EVYN DATA OÜ may collect, use, cache and transfer the following information where users have chosen to furnish us with the same:

• *If you create an EGO VPN Premium account we will collect your email address, username and password. If you create a free account we will only collect a username and password. We do not require any further information to use our products or services.
• *If you choose to contact us we may collect your email address and additional Personal Information you may provide.
• *We will agglomerate data concerning your communication preferences and preferences as to whether you wish to receive marketing communications from us, our affiliates, third party service providers or partners.
• *Should you elect to purchase a subscription for a premium account, all payment information will be collected by the app store where you make your purchase, either the Apple App Store or Google Play Store as appropriate to your chosen platform. EVYN DATA OÜ will not collect any data pertaining to payments.

Automated Information Collection Technologies or Interactions – what data is collected?

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

• *When the EGO VPN app is launched we and our third party service providers may accrue device-specific information such as your unique mobile ID, which operating system you are using and on which platform, your web browser type and version, networking information and other technology on the device you use to access the Website or the Services.
• *When you connect to EGO VPN, we capture your IP address, which we pseudonymise, immediately encrypt and store it only for the duration of that specified VPN session. Once you disconnect from the session, your IP address is immediately deleted and will not be logged. We do not create any association between your IP address and your online activities nor do we store or register your IP address or any information about your online activities.
• *We may collate aggregated and non-personally identifiable information about your use of our Services and Website. No particular website visits or explicit app usage patterns are linked in any way to any distinct user. We maintain no logs of users’ online activities and do not associate the domains, website addresses or applications that you use with you, or your personally identifying information.
• *Where you act to make a payment or transaction, we may accumulate data about payments to and from you and details of the respective products and services you have bought or received from us.
• *We may also acquire, use and share your data to produce and share aggregated datasets that do not identify you. As an example of the type of data to which we refer, we may collate your usage data along with others to calculate the proportion of users exploiting a singular feature, to generate statistics about the use of our products or services or to monitor clicks on advertising items.

Our Website – what data is collected?

• *When you are navigating the Website, we use automated collection technology to gather data pertaining to your physical equipment, your device IDs or application IDs, unique mobile ID, advertising ID, operating system and platform, browser type and version, internet service providers, mobile network names and cookie information. We may use this data in order to make improvements to the Website or Service and for the purposes of analysis and error correction.
• *The same technology is employed in order to gather data related to your online activities over time, whether that’s on other webpages or through online services including web-based advertising. You can see more detailed information below on your rights pertaining to tracking, how you can opt out of being traced and browser settings which allow you to manage this.
• *For the most part your use of the Website does not require the submission of personally identifying data, however we may use cookies on our own behalf or that of a third party in order to analyse and understand how users are accessing our website and their movements throughout the available pages.
• *If you wish to disallow the use of cookies, you can consult the help section of your chosen browser to find out which setting you need to change to achieve this. You may also wish to be notified of cookies on a case by case basis, and approve or disapprove them as necessary. You should note that while you will still have access to the Website, there may be features or elements which are unavailable or do not work as intended without the use of cookies.
• *Analytics. We use third party analytics and advertising tools, in particular Google Analytics, and Firebase and AppsFlyer (for Services only). Google Analytics and Firebase are provided by Google, Inc., USA (“Google”). These tools and technologies may retrieve 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 digital storage 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 infrastructure in the USA. 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 Google (for both Google Analytics and Firebase) or by AppsFlyer, see below.
• *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.
• *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.

Third Party Advertising

Users of the free version of EGO VPN will see generic advertising placed by our advertising partners, for example MoPub (with Twitter as its parent organization). Users of EGO VPN Premium will not receive any advertising, nor have any information shared with advertising partners.

Third-Party Use of Cookies and Other Monitoring Technologies

Some content, including advertisements, visible through the Services is supplied by third party companies, which includes advertisers, ad networks and servers, content providers and application providers. These organisations may track or gather information on your use of the Website or Services. We do not share any personal information about our users with these third parties, and any information they obtain themselves, their analysis and use of that information, will be covered by their own privacy policies. Get in touch with the pertinent provider directly if you have any questions pertaining to the collection and use of your personal information.

Our use of your personal information will always be carried out in compliance with local laws and data protection requirements. Depending on the distinctive purpose of the activity we undertake, we may justify our use of your information on one or more legal grounds.

In most cases, except for direct marketing communications we do not rely on consent as a legal standpoint for processing your data.

We neither sell nor rent personal data which we have collected to any third party, nor do we archive any browsing data. Once you have disconnected from the VLN service, we do not maintain a record of your IP address.

Our use of personal data collected about you is limited generally to the following use cases: account creation, communication with our subscribers, provision of maintenance or troubleshooting services, sending electronic communications related to account status or to our provision of the Service or Website, and to notify you about changes or additions to this policy and/or to our terms of service.

Other potential uses include but are not restricted to:

• *identity verification to allow you to log in to and use the Service
• *administration and maintenance of the Service
• *provision of information, products or services that you request from us;
• *provision of custom content and/or advertising tailored to your interests
• *communication of advertising material where you have given your consent for this
• *analysis of the use of our service in isolation and on an aggregated level
• *our own internal business processes, including audits
• *for the identification and detection of fraudulent or illegal activity or IP infringements
• *for compliance with legal and regulatory duties;
• *for our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests;
• *in any other way we may describe at the time we gather the data or for any other purpose for which you give explicit consent outwith the terms of this policy.
• *with third party service providers such as for processing payments. In this case we share only the information necessary to execute the designated functions.

We do not share your personal information with any third parties for their own marketing, advertising or research purposes.

Security

We deploy a range of security measures, including physical access controls, electronic protection and defined security processes to avoid theft, loss or interception of your data. Our staff and third party partners are training regularly on the apposite procedures.

However, no data security methods can 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 circumvention of any privacy settings or security measures contained on the Services.

Disclosure of your Personal Information

There are only certain circumstances in which we would disclose you data, those are laid out below:

• *Where necessary we may share certain germane data with service providers as needed for them to perform functions necessary for the delivery of the Service, and only for such purposes.
• *If we sell or transfer our assets to a buyer or successor, through sale of the company, merging with another company or entering administration. If that occurs we will make every reasonable effort to ensure the successor organisation maintains the terms of this policy.
• *With regulatory bodies or law enforcement agencies where necessary to comply with local laws, government or court requests or for the purpose of bona fide investigation into criminal activity, or to maintain the privacy and security of the Service.
• *In the form of aggregated or non identifiable information in order that we or another party may conduct business analysis and for the purpose of improving the Service.

When you use the Service or access our Website, you give your consent to the transfer of your data to, and processing of your information in, Estonia or other countries as necessary.

We retain your data for as long as is necessary to fulfil the purposes described herein.

The period for which we retain your data is decided on a number of factors, including the corresponding legal and regulatory environment in the territories in which we operate, and may vary in character. Where we no longer require your data, or where requested by you assuming any other condition for legal retention does not apply, we will permanently and irreversibly delete it.

• *When creating an account with our Service you will have the option of choosing to receive certain communications from us, relating to marketing, product information, special offers, etc. Should you wish to update your preference in this regard, consult the unsubscribe information in the topical communication. Some transactional or administrative communications may not be opted out of if they are necessary for the proper and legal delivery of the Service.
• *If you delete your account we will delete all personal information we hold about you, as long as this does not conflict with our statutory legal obligations.

Your Rights

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

Your rights regarding the data we collect from you are as follows (contingent upon local and/or national legislation and regulation)

• *to know what data of yours we have and how we use it
• *to correct any inaccuracies in the data we hold about you
• *to delete that information permanently
• *to procure a copy of that information in a commonly usable format
• *to object to the use of that information
• *to place restrictions on how we manipulate that information

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.

The consent you give for us to use your data can be withdrawn at any time by contacting the email address at the end of this policy. It may be the case that if you do not mandate us to examine or retain certain data we will no longer be able to adequately deliver the service, and it may be necessary to delete your account. You can also reach your local data protection body for advice on these matters if you are located in the EEA.

Use of Services by Minors

The Service is not authorised for use by persons under sixteen years of age. Where use of the service by a minor is detected, all linked accounts and information will be removed and deleted.

This policy may be changed or updated as necessary. See the revision date at the top of this page for information about the recency of the information herein. Review this page regularly to stay updated.

If you wish to discuss any aspect of this policy or to direct a complaint regarding our activities in upholding the policy, or our use of the data described herein, please email support@evyndata.com. We respond in writing to all formal complaints and fully cooperate and comply with regulatory and data protection authorities in order to resolve them.

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 accept no responsibility or liability for errors in the handling of this policy, and shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.