Last updated: 07 July, 2022
We, 2GoodApps OU are committed to protecting your privacy. We strictly limit the collection scope of your data. Only data required to maintain our service is collected.
1. COLLECTION OF DATA
1.1 Data NOT to be collected
We do not collect the following data:
We do not collect sensitive data as we have engineered our systems to categorically erase the storage of sensitive data.
We do not collect any data related to your online activities. We do not collect data logs of your activities, including:
We do not collect data of your connection logs, including:
As we do not collect data logs of your activity or connection logs, we would not have information about:
1.2 Data to be collected
We limit the collection of your data. We only collect data that is required to maintain the services by HQ VPN.
1.2.1 Data provided to us
We collect the data that you provide to us through your interaction with HQ VPN. When you register for an Account, we may ask for your email address. The amount of data that you provide us depends on your privacy settings.
We use your email to:
If you contact us directly, we may receive data such as your name, email address, phone number, content of the message and/or attachments, and any other personal data you may choose to provide to us in your communication to us.
You may withdraw your consent to our use of your email address for the above purposes.
1.2.2 Data necessary for us to maintain the service quality of HQ VPN
We collect the following data related to your use of HQ VPN:
2. USE OF DATA
We use, combine, and process your data for the following purposes:
We authenticate your use of HQ VPN by assigning a unique identifier to you when you register for the service via your email address. This unique identifier, without reference to other data, identifies you through your device identification code. The purpose of the unique identifier is for us to determine the level of service you have signed up for before we establish your HQ VPN connection.
We do not use any other forms of your data to verify your identity.
2.2 System diagnostics
We use the data related to your HQ VPN usage to perform internal operations necessary to maintain services of HQ VPN. This includes operational troubleshooting, conducting data analysis & activity trend analysis.
2.3 Customer support
We use your data to resolve customer support issues. For example, we may investigate and address concerns, monitor and improve our customer support, respond to your questions and feedback, and inform you of suggestive steps to resolve certain regular customer issues.
We may communicate with you to provide updates relating to HQ VPN, and for marketing & promotional purposes.
2.4 Research and development
We use your data to understand and analyze your use of HQ VPN to develop new products, services, features, and functionalities for you.
2.5 Service providers
We use data from service providers and third-party vendors to provide and market HQ VPN.
3. SHARING AND TRANSFER OF DATA
We share and transfer your data in various ways, including the following:
3.1 Aggregated anonymous data
We use and share your data with our partners in aggregated or anonymized form that cannot be used to identify individual users.
We share and transfer your anonymized statistics and analytical data for network diagnostics.
3.3 Business transfers
Your data may be disclosed and otherwise transferred to potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership.
3.4 With your consent
With your consent and instruction, we may share your data.
3.5 International data transfers
We may process your data to any countries in which we engage service providers. You hereby acknowledge the transfer of your data outside of the country where you reside. We will ensure that your data is well protected before the transfer.
4. SECURITY MEASURES
We implement robust security measures to protect your data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. We ensure the security of our computer networks and sound adoption of control measures. Access of our staff to your data is restricted to a strict need-to-know basis.
We do not collect or store any traffic data or personal data in our data centers.
5. DATA RETENTION
We retain your data on the condition that we have a legitimate ongoing business need to do so, such as providing you with service you requested, or complying with applicable legal, tax, or accounting requirements.
When there is no legitimate ongoing business need to process your data, we will delete or anonymize it. If it is impossible to delete or anonymize your data (for instance, because it has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is feasible.
6. RIGHT TO BE FORGOTTEN
We will erase your data when:
7. THIRD PARTY SERVICES
You may access other third party services while using HQ VPN, for example, by clicking on links of third party services from within HQ VPN. We shall not be held responsible for the privacy policies and/or practices of these third party services. You are encouraged to carefully review their privacy policies.
1) Paid HQ VPN
For paid HQ VPN, we do not work with third party advertising partners.
2) Free HQ VPN
For free HQ VPN, we work with third party advertising partners to offset the cost of providing our services. We do not target advertisements based on your data. We do not share or use your data in connection with third party advertisers without your prior consent.
Third party advertising partners may set and access their own cookies, pixel tags, and similar technologies on our services, and may otherwise collect or have access to data about you which they may collect over time and across different online services.
9. CHILDREN'S PRIVACY
We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents or guardian's prior permission.
We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.
If we consider that any of our services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the services or from providing information and/or limit the collection of information from such users as described below in more details.
No personal information should be submitted to HQ VPN by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that does not meet the minimum legal age required in their state of residence.
Such a user cannot:
l display their real name or any information in HQ VPN
l access the chat, leader board, forums, SNS (Meta, etc.)
l subscribe to newsletters
l use any other feature where users real names might appear
With respect to such users, we will prevent the collection and use of their precise geolocation data and display to them contextual advertising only (excluding any behavioral advertising).
Children can be invited to take part in testing our websites & apps with their parents or guardians authorization and/or their parents or guardians physical presence being required depending on the state where testing is conducted.
When you become a user of HQ VPN, you may request access to your data that is associated only with you by emailing email@example.com .
To protect your privacy and security, we may take reasonable steps to verify your identity before acceding to your request. Upon our approval of your access request, we will provide you with your data that is in our possession or under our control. Where applicable, we will provide you with information about the ways in which your data has been or may have been used or disclosed by us within a year of your request. We may charge you a fee for fulfilling the access request.
You may make a request to correct an error or omission about your data that is in our possession or control, by emailing firstname.lastname@example.org.
We will consider whether the correction should be made. If such correction is to be made, we shall correct your data as soon as practicable and send the corrected data to every other organization to which your data was disclosed by us within a year before the date the correction request was made, unless that other organization does not need the corrected data for any legal or business purpose.
To protect your privacy and security, we may take reasonable steps to verify your identity before correcting your data. Your data may be archived or stored periodically by us according to backup processes conducted in ordinary course of business for disaster recovery purposes.
If you are a resident of the EEA, we ask that you keep the information that you provide to us updated. You can correct any information you have provided by contacting us by email email@example.com.
You represent and warrant that all information you provide us is true and correct, and that the info relates to you and not to any other person.
You can exercise your rights at any time and ask HQ VPN for access to, or rectification or erasure of, your information.
Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us by emailing firstname.lastname@example.org .
If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.
Please note that VPN functionality, services and features can be affected by your actions. Some of your information and processing thereof is mandatory for HQ VPN to provide the services.
Your actions may force HQ VPN to cease providing services. When the conditions below apply, services will be reset:
Please specify your request by emailing email@example.com .
If you are the parent of a child who is under 13 years of age (or under another age specified by applicable regulations) and believe your child has provided us with improper information, please email us at firstname.lastname@example.org and we will delete the information from our systems.
To preserve the confidentiality of your information, we must be able to correctly identify you. For this reason, please provide us with a copy of an official document to prove your identity. This copy will be safely destroyed within two months of your request being received and closed.
Our team will look into your request and answer you within one month, unless your request requires further investigation, in which case you will be specifically informed.
The California Consumer Privacy Act of 2018 (CCPA) permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year.
As a Californian consumer, you also have the right, at any time, to opt out of any type of selling your personal information.
14. BREACH NOTIFICATION
We will report serious breaches of your data security to relevant supervisory authority to ensure the effective protection of your data.
If we materially change the ways in which we use or share your data previously collected through HQ VPN, we will notify you through HQ VPN, email, or other communication.
16. GOVERNING LAW
17. DATA PROTECTION OFFICER
Oleg Golovachov is our Data Protection Officer ("DPO"). The DPO may be contacted at email@example.com .
18. DELETE YOUR INFORMATION
To remove your account, you must send an e-mail to [firstname.lastname@example.org] with your specific account information.