Privacy Policy

As the operator of 724 VPN, we understand the importance of personal information to you. We will protect your personal information and privacy security in accordance with laws and regulations. We have formulated this "Privacy Policy" and specifically remind you to carefully read and understand it before using 724 VPN and related services, so that you can make appropriate choices.

This document (“Privacy Policy”) explains the privacy rules applicable to personal data and other information collected or submitted when you access, install, or use 724 VPN Services and APP regardless of the device (computer, mobile phone, tablet, etc.) you use.

The data controller of your personal data, as described in this Privacy Policy, is 724 VPN. (address: 35 Pond Street, London, England, NW3 2PN; email: [email protected]) (“724 VPN”, “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 APP, by submitting your personal data to us, and by accessing, installing and/or using our Services, you confirm that you have read this Privacy Policy and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy or any provisions hereof, please do not use our Services and APP.

Additional information on your personal data may also be indicated in contractual terms, supplemental privacy statements, or notices.

1. PROCESSING OF YOUR PERSONAL DATA

724 VPN processes personal data to a limited scope to provide Services process payments for the Services and enable the functioning of our APP. We may process the following categories of personal data:

Information for creating your Account

• Email address. We ask for your email address as part of your registration. It is necessary for the creation of your 724 VPN Account retrieving a lost password and using the Services.
• Subscription information
• Subscription data. When you subscribe to our Services we process certain subscription information (e.g. your email address the subscription plan you have chosen subscription term subscription ID subscription frequency amount currency status auto-renewal status information about enabled/disabled features such as multi-factor authentication (MFA) etc.).

Communication data

• Email address. We use your email address to: i) send you important updates and announcements related to your use of the Services and APP; ii) respond to your requests or inquiries; iii) send you offers surveys and other marketing content (you can opt-out of those at any time).
• Customer support inquiries. We keep the information that you provide to our customer support team that was necessary to resolve the query. Depending on what information is necessary it can consist of but not limited to: payment information for customer verification processes your country name information of your OS local application logs etc.
• Communication optimization data. We use various tools to help us optimize our emailing campaigns. These tools may track actions you perform with an email such as open it or unsubscribe from further communication. We may also be able to see the user device’s operating system (e.g. Windows Mac iOS Android) and country in order to optimize push and email notifications and automatically set the language.

Information collected on our applications and APP

• Service usage. We collect information about specific 724 VPN Services (724 VPNVPN 724 VPNPass 724 VPNLocker etc.) and features you use.
• Access logs. As most APP on the internet our APP collect access logs (such as IP address browser type operating system) to operate our Services and ensure their secure reliable and robust performance. This information is also essential for fighting against DDoS attacks scanning and similar hacking attempts.
• Cookies. Cookies pixels and other similar technologies are usually small text or image files that are placed on your device when you visit our APP. Some cookies are essential for our APP to operate smoothly; others are used to improve APP’ functionality analyze aggregated usage statistics to improve APP’ performance and for advertising. We also use affiliate cookies to identify the customers referred to our APP by our partners so that we can grant the referrers their commission. You can check what cookies we use at our Cookie policy.

2. GROUNDS FOR PROCESSING OF PERSONAL DATA

Your personal data is processed:

• Where it is necessary to fulfill our contract with you at your request. Such cases include: i) to provide access to our Services; ii) to process your purchase transactions; iii) to ensure the secure reliable and robust performance of our Services and APP.
• When we have a legal obligation to process certain personal data collected from you (e.g. to keep and process records for tax purposes and accounting).
• Where you have provided your consent to us. Such cases may include: i) to send marketing communication (unless applicable law permits us to contact you without your prior consent); ii) to communicate with you and manage your participation in 724 VPN’s contests offers referrals or promotions. Please note that although 724 VPN may also process your personal data for marketing purposes when applicable law permits us to contact you without your separate consent if you choose not to receive marketing communication from us (i.e. if you opt-out) we will honor your request.
• We sometimes may process your personal data under the legal basis of our or third parties’ legitimate interest. Such cases include: i) to properly administer business communication with you; ii) to detect prevent or otherwise address fraud abuse security or technical issues with our Services and APP; iii) to protect against harm to the rights property and safety of 724 VPN our users or third parties; iv) to improve or maintain our Services and provide new products and features; v) to receive knowledge of how our APP and applications are being used (crash reports app store reviews information about the channel from which our app was downloaded etc.).

3. SHARING YOUR PERSONAL DATA

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

3.1 724 VPN partners.

Sometimes our partners for example distributors resellers and app store partners will be independent data controllers of your personal data. In such cases the procedures established by them (e.g. terms of service and privacy policies) will apply to such relationships. In other cases we may collaborate with partners as joint controllers meaning that we jointly define the purpose and means of data processing with them. Both joint controllers are then responsible for the data processing and its compliance with applicable privacy laws. We also partner with third parties to display advertising on our APP or to manage our advertising on other sites. These partners help us deliver more relevant ads and promotional messages to you which may include behavioral contextual and generic advertising. We and our advertising partners may process certain personal data to help us understand your preferences so that we can deliver advertisements that are more relevant to you. Your personal data may be processed in any country in which we engage service providers and partners. When you use our Services and APP you understand and acknowledge that your personal data may be transferred outside of the country where you reside.

3.2 Protection of our rights.

We may disclose personal data to establish or exercise our legal rights or defend against any legal claims or other complaints. We may also share such information if we believe it is necessary in order to investigate prevent or take action regarding illegal activities suspected fraud and violations of our General Terms.

3.3 Business transfers.

We may share your personal data in those cases where we sell or negotiate to sell our business or go through a corporate merger acquisition consolidation asset sale reorganization or similar event. In these situations 724 VPN will continue to ensure the confidentiality of your personal data.

3.4 Requests for data.

Any request for user data should follow an appropriate official legal process recognized by the laws of UK (e.g. mutual legal assistance treaty letters rogatory). We carefully review each request to make sure it satisfies laws applicable to our company laws of requesting country international norms and our internal policies. However it is important to note that the laws of UK do not oblige us to store logs of users’ online activity. Accordingly we do not log users’ browsing history traffic information or IP addresses used to access the internet via our services. This means that we are not able to link shared IP addresses of VPN services to an individual user or otherwise individual users based on data that we do not process. Therefore even if we were to receive a rightfully served request it might be impossible for us to identify a specific person or provide any identifying information related to that person. In cases where following an appropriate legal process we are obligated to comply with a request and we are able to identify a specific person we will provide the limited data we process as per our Privacy Policy given it falls within the scope of the request.

3.5 Cross-border transfers of personal data

To facilitate our Services and APP we may store access and transfer personal data from around the world including in countries where 724 VPN has operations. These locations may not guarantee the same level of protection of personal data as the one in which you reside. We assess the circumstances involving all cross-border data transfers and have suitable safeguards in place to require that your personal data will remain protected in accordance with this Privacy Policy. For example in case your personal data is transferred to countries outside the EEA we make sure there is an adequacy decision from the European Commission with regards to the recipient country or we use standard contractual clauses approved by the European Commission for such transfer of your personal data.

4. CHOICES RELATED TO YOUR PERSONAL DATA

Please note that there are various data protection laws across different jurisdictions that provide privacy rights to you as a data subject. Subject to those applicable data protection laws among others you may have the following rights:

• Delete: request us to erase your personal data;
• Access: know and access personal data 724 VPN has collected about you;
• Rectify: rectify correct update or complement inaccurate/incomplete personal data 724 VPN has about you;
• Object: object to the processing of your personal data which is done on the basis of our legitimate interests (e.g. for marketing purposes);
• Portability: request us to provide you with a copy of your personal data in a structured commonly used and machine-readable format or to transmit (if technically feasible) your personal data to another controller (only where our processing is based on your consent and carried out by automated means);
• Restrict: restrict the processing of your personal data (when there is a legal basis for that);
• Withdraw consent: withdraw your consent where processing is based on a consent you have previously provided;
• Lodge a complaint: exercise your rights by contacting us directly or if all else fails by lodging a complaint with a supervisory authority.

Rectification. If you’d like to edit your profile information (e.g. change your email address add additional username) please contact our support team at [email protected].

Access/Deletion. If you wish to delete your Account or your personal data that we process or request to provide you with a copy of your personal data please contact us at [email protected].

Please note that you will need to pass through the Account verification process so that we can verify you are the owner of the Account before taking further action on your request.

724 VPN's Obligations on Termination. Upon expiration or termination of your Account and/or Subscription 724 VPN will immediately cease processing information that’s associated with you. However please note that there might be cases when we retain information associated with you after expiration or termination of your Account and/or Subscription: (i) all 724 VPN products' databases are connected; after expiration or termination of your Account basic information (such as your email address) would still be visible in our system in case you have another existing Account associated with a different 724 VPN product (e.g. if we delete your 724 VPNPass Account your email address would still be visible in our system if you have a 724 VPNVPN or 724 VPNLocker Account). In order to delete all of your data we would need to delete all of your Accounts associated with different 724 VPN products (in order to do so please contact our support team); (ii) 724 VPN also may retain information associated with you (e.g. payments data) in order to fulfill its obligations as required by applicable laws regulations court orders subpoenas or other legal processes for archival purposes.

Opt-out. If you wish to unsubscribe from our communication you can opt out at any time by clicking the “unsubscribe” link at the bottom of each email or contacting us at [email protected].

You can control the use of cookies at the individual browser level on your device. To disable cookies follow your browser’s instructions on how to block or clear cookies.

If you do not agree with the processing of your personal data by 724 VPN please do not use our Services and APP. You can request us to discontinue processing your personal data in which case your data will be processed only as much as it is necessary to effect the discontinuation of your use of the Services (e.g. final settlement or deleting all personal data based on your email address) or finalizing other 724 VPN’s legal relationship with you (e.g. record keeping accounting processing refunds). Please note that we or our third-party service providers may be obliged to retain your certain personal data as required by law.

To raise any other questions concerns or complaints about our privacy practices or about our processing of your personal data please contact us as provided below (Section “Contact Us”).

5. Device Unique Identifier and Keychain Data Collection and Usage

To enhance user experience and ensure the proper functioning of the app, we use a device unique identifier (UUID) and store it in the iOS Keychain. Below are the details of how we use this data:

• Data Collected: When you first launch the app, we generate a random device unique identifier and securely store it in the Keychain. This identifier is not linked to your personal information and is only used to distinguish your device.
• Data Usage: We use this unique identifier as the unique ID for your device to manage app usage status (e.g., key generation), ensuring consistent user experience even after app reinstallation. This identifier is used solely within the app and is not used for cross-app or advertising purposes.
• Data Storage and Security: The unique identifier is securely stored in the Keychain and encrypted by the system. Even if you delete the app, the data will not be automatically erased unless you manually reset your device or clear the Keychain data. We will not share this data with third parties, nor will it be used for any purposes without your consent.

6. DATA SECURITY

We maintain tight controls over the personal data we collect. Our dedicated IT security team has implemented appropriate physical technical and organizational measures to protect information about you against accidental or unlawful destruction or accidental loss alteration unauthorized disclosure or access and against all other unlawful forms of processing:

Physical Measures. We control access to our facilities with access cards.We also use security alarm systems and CCTV. We store devices with personal data information only in locked rooms or cabinets. Our printers are protected by access control measures. A clean desk policy is implemented.

Technical Measures. We use layered defense with firewalls anti-malware protection intrusion detection and prevention systems. Our infrastructure is regularly updated and regular vulnerability scans are in place to detect possible vulnerabilities. We have security event and incident management solutions to correlate and investigate signals in security tools. Servers are hardened and automated configuration tools are used to manage them. All workplaces are managed from a centralized endpoint management tool. Data at rest and in transit are encrypted. Encryption protocols are used according to the newest security practices.

Organizational Measures. We adopted information security and data processing policies according to best practices. We have external audits to prove our information security and data processing policies are up to standards. We adopted a constant development culture of security and data protection awareness among our employees (including organizing regular and ongoing training and other awareness activities).. We analyze the threat landscape and attack surface and constantly update our security measures. Access to databases containing personal data is granted on a need-to-know basis.

If we detect something suspicious we will notify you immediately and guide you through steps to stay better protected. However no company can guarantee the absolute security of internet communications as no technology is completely bulletproof. By using the Services and APP you expressly acknowledge that we cannot guarantee the 100% security of personal data provided to or received by us through the Services and that any information received from you through APP or our Services is provided at your own responsibility. If you have any reason to believe that your interaction with us is no longer secure please notify us at [email protected].

7. DATA RETENTION AND DELETION

724 VPN will keep your personal data only as long as necessary to provide you with the Services or for as long as we have another legitimate ground to do so but not longer than permitted or required by law.

When we no longer have a legal ground to keep your personal data it will either be securely disposed of or de-identified through appropriate anonymization means. 724 VPN will destroy personal data recorded or stored in the form of electronic files using method(s) that would prevent the recovery of the data.

8. CONTACT US

If you have questions requests concerns or complaints about this Privacy Policy or our personal data processing practices or you wish to exercise your data subject rights please contact us via [email protected].

9. CHILDREN’S DATA

724 VPN 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 about yourself to 724 VPN. If we acknowledge that we have collected and processed personal data from a child under the age of 18 we will delete that data as quickly as possible.

10. OTHER TERMS

10.1 Limitation of Liability. To ensure the security of personal data 724 VPN employs various technical physical and organizational security measures; however it is your responsibility to exercise caution and reason when using the Services and APP. You will be personally liable if your use of the Services and APP violates any third party privacy or any other rights or any applicable laws. Under no circumstances is 724 VPN liable for the consequences of your unlawful willful and negligent activities and any circumstances that may not have been reasonably controlled or foreseen (please read the General Terms for more information).

10.2 Links to other APP. Our APP may include links to other APP (e.g. social media APP) whose privacy practices may be different from ours. If you access any of those APP via such links and/or submit your personal data to any of those APP your personal data is processed by the procedures established by them and governed by their privacy policies. We encourage you to carefully read the privacy policy (or other respective privacy notice) of any website you visit.

10.3 Prevailing Language. For all purposes the English language version of the Privacy Policy shall be the original governing instrument and understanding between you and us. In the event of any conflict between this English language version of the Privacy Policy and any subsequent translation into any other language the English language version shall govern and control.

10.4 Updates to the Privacy Policy. We develop our Services and APP introducing new features or modifying current ones constantly. Therefore we may need to amend the Privacy Policy from time to time. If the amendments to the Privacy Policy materially affect the activities of our processing of your personal data we will notify you in advance of such changes by reasonable means (e.g. notification through the respective applications our APP or via email) and we will always indicate the date of the last update. Unless it is stated by us otherwise each update of the Privacy Policy comes into force as of the moment when the amended Privacy Policy is published on this Website. You are expected to check this Privacy Policy regularly so that you are familiar with the most current wording of the Privacy Policy. Your continued use of the Services and APP will be deemed acceptance thereof.