VeePN Privacy Policy

We care about your personal data, so in this document we have detailed what data we collect and how we use it, what information we do NOT collect, and how we work with third parties.

Our data protection principles are only concerned with collecting the minimum data necessary to operate a VPN service. Our applications are designed so that they do not require the sensitive data of our users.

This Privacy Policy is aimed to inform you (“you”) — a user of VeePN Corp. Service — how we, VeePN Corp. (“Application”, “App”, “Services”) with registered office at Samuel Lewis Ave & 55th Street, PH SL55 Building, 21st Floor, Panama, Republic of Panama, collect and use your information when you use our Services. For payment processing, VeePN partners with Laraun Limited (Cyprus) and IT Research LLC (USA), which may process certain personal information necessary to complete your transactions. We only use your information as described in this Privacy Policy, and we won't share it with anyone except as described here. This Privacy Policy is subject to our Services Terms of Service.

By choosing to use our Service you explicitly: (I) agree to the collection and use of information concerning this policy, (II) warrant and guarantee that you are over 18 years of age (or are a parent or guardian with such authority to agree to this Privacy Policy for the benefit of an individual under 18 years of age). Please do not use the Application or access the Services provided by it if you do not agree to this Privacy Policy.

What kind of information we collect

Important Notice

We're a VPN service based in Panama City, which privacy-friendly jurisdiction that allows us to not store our VPN logs. We never collect IP addresses and logs of your activity (“usage logs”), which means we don't track or store your browsing history, network traffic, or other similar data. We work with tools such as Google Analytics. You can learn more about the Google Analytics Privacy Policy here: https://policies.google.com/privacy.

When you sign up for our VPN service, we receive your data so we can verify your account and help you restore it if needed. We may collect information that directly identifies you, such as your name and email address (which you specified when registering) (“Personal Information”), and other information that does not identify you as listed below.

Information you provide

We may collect the contact information you provide, such as name and email address, when you register and use the Service or provide it to us in some other manner. For example when you correspond with us (by email or chat, for instance), when you report a problem with the Service, when you subscribe to any of our services, or agree to the mailing.

This information is collected to administer your VeePN subscription and includes your name, email address, and payment information, which you submit on our order page when you subscribe for the Services.

Note

Information about a third party. When you provide us with information about a third party, you must have that third party's consent before doing so. By providing us with information regarding a third party you confirm that you have their permission to give that information to us.

If our application fails for any reason, we may also ask you to send us a crash report so that your problem can be resolved as quickly as possible.

Information we collect on our website and apps

All of the information below helps us identify problems with our servers and our site. All information is used for marketing purposes and user analytics, and it’s not connected to the user's personal information.

When you approve the tracking of your data, in particular, we collect only the Wi-Fi name (Service Set Identifier), Wi-Fi status, OS version, device type, and model ("Technical Information").

You can reset your ID or opt out of personalized ads by changing your device settings.

When you use our applications, we can collect an advertising ID. It is a unique identifier for displaying relevant ads and other marketing offers.

Device information. It can include specific information about your device (for example, OS version or hardware model), information about your use of features, etc. These number values are not permanently tied to your device. Also, depending on your OS, you can reset it through your device settings. Besides, to provide our antivirus service (available on Windows and Android as of now), we also collect information about the devices on which you use the antivirus. We need this info to make sure that the limit of the device slots that one client may use for the antivirus service is not exceeded (as provided in our Terms of Service). We may also process malware name and type, country, OS, and user ID to provide statistics on what malware was detected.
Email / phone information. If you use the Breach Alert feature as a part of the VeePN Security Bundle, you can provide your phone number / email address to monitor it for data leaks. If you decide to let us monitor your phone number / email, you also allow us to use additional information related to it (usernames, full names, passwords, country, IP address) that could be exposed in a breach. We use this information to detect when your phone number / email or the data associated with it is noticed in a security breach. If we identify a breach involving your data, we will promptly notify you via the email address you provided. We store this data encrypted and are unable to view or use it in any way outside of the main purpose of the relevant feature.
Usage information. This includes your user account registration date and time, information about the use of the App (such as frequency of use, engagement with particular features, which sections of the App user visits, and your common use patterns). Please note that wording 'usage' does not in any case mean that we collect your usage logs.
Cookies. A cookie is a small amount of data stored on your computer used as an anonymous unique identifier. When you visit our website veepn.com (“Website”), we may collect information from you automatically through cookies or similar technology.

In particular, we use cookies to recognize you on our Website and remember your previously selected preferences. Please note that our use of cookies does not in any way relate to your use of our Services but only to your interaction with our Website itself.

If you want to prevent cookies from being saved, you can select the “Accept no cookies” option in your browser settings. To find out exactly how this works, you can refer to your browser instructions. You can delete cookies that have already been saved on your device at any time. However, in a few cases, some of the Website features may not function as a result.

What do we collect this information for

Providing you with the best user experience on our Service by operating, maintaining, and giving you access to all features of the Services;
Managing your account and providing you with customer support. We may use your Personal Information to respond to your requests for technical support, Services information, or to any other communication you initiate (“Customer support purposes”);
Analytics purposes and performing research of your interest in our products, services, content, or by-products, services, or content offered by others;
Communicating with you via email, push notifications, and/or other digital methods about products or services that may be of interest to you either from us or other third parties;
Detecting and resolving any fraud or other illegal or undesirable user behavior.

Besides, to maintain the quality of our VPN service, we need to use third-party resources, with their own conditions and policies.

We may reach out to you via email to offer you the best VeePN deal, but we also recommend that you get in touch with us through our online contact form. To efficiently address your needs, we may ask you to provide us with some information about yourself. Additionally, we will utilize the information you provide to notify you of any future offers that may be of interest to you.

In case you prefer not to receive emails from us, you can opt out or unsubscribe by emailing us at [email protected] or clicking the "unsubscribe" button located at the bottom of any email communication. If you have multiple email addresses, please opt out of each address to be removed from our active database.

Your consent, your existing relationship with VeePN, or our legitimate interest in carrying out marketing activities serves as the legal basis for processing your personal data.

With whom do we share this information and how may we disclose it

All third-party services we work with use the minimum amount of your data, which are specified in paragraph 1 for quality service of your needs. Here is the general list of our main long-term service providers:

Third-party provider	Purpose	Country of residence
Infrastructure Providers such as Amazon Web Services (AWS), Google Cloud Platform (GCP) and DigitalOcean	Storing information, overseeing server and domain management, as well as hosting our servers and networking equipment	United States
Emailing service providers such as Sendgrid	Sending and managing emails	United States
Live chat and Support service providers, such as Zendesk and Tidio	Providing of user support, live chat and support bot technology	United States
Payment Providers such as PayPal, Paddle, BlueSnap, Apple, Google and similar	Processing of payments, in-app purchases and subscriptions	United States
DNS, CDN & Security service providers such as Cloudflare, Akamai Technologies, Amazon Route 53, OpenVPN, OpenSSL, Let's Encrypt	Aiming at enhancing security measures and contributing to the optimization of service performance, user data protection	United States
Marketing service providers, analytics and diagnosis such as AppsFlyer, Amplitude, Google Analytics, Clarity	Enhancing our marketing efforts, tracking the effectiveness of advertising campaigns, analyzing our app's performance fixing bugs, improving our product	United States
Legal advisers, attorneys, notaries, bailiffs	Enforcing and defending our rights and legal interests	Panama, United States, Cyprus

Personal data may be disclosed for the purpose of asserting our legal rights, mounting a legal defense against claims or complaints, and potentially sharing such information when we deem it essential to investigate, prevent, or address unlawful activities, suspected fraud, and breaches of our Terms.

Your personal data might be shared in scenarios where we are involved in the sale, potential sale, or negotiation of our business, or in the context of a corporate merger, acquisition, consolidation, asset sale, reorganization, or similar event. In such instances, We remain committed to upholding the confidentiality of your personal data.

Payment Processing Partners

VeePN collaborates with independent payment processing partners, including Laraun Limited (Cyprus) and IT Research LLC (USA), which facilitate payment transactions for our services. When necessary for processing your payment, certain personal information (such as name, email address, payment details) may be shared with these payment service providers. These partnerships enable us to provide our services globally while meeting various regional payment requirements. All payment partners are contractually obligated to handle your data in accordance with applicable data protection laws and may only use your information for the purpose of processing payments for VeePN services.

Data Sharing with App Store

We may request your consent to share specific data about your app usage with the App Store. This data is used to improve user experience and assist in processing refund and dispute requests. The information provided to the App Store may include:

Details of your subscription and usage patterns;
Transaction-related information (excluding payment details);
Other relevant technical data as required by App Store Server API;

You will be explicitly asked for your consent before any data is shared. If you choose not to provide consent, it may affect the processing of refund or dispute requests submitted through the App Store.

You can manage your consent preferences at any time within the app settings. Revoking consent does not affect data previously shared with the App Store.

Information disclosure

Any request for user data must adhere to an official legal process that is recognized by the laws of the Republic of Panama, such as a mutual legal assistance treaty or letters rogatory. Each request is meticulously reviewed to ensure its compliance with our company's applicable laws, the laws of the requesting country, international standards, and our internal policies.

It is crucial to understand that the laws of the Republic of Panama do not impose an obligation on us to retain logs of users' online activities. Consequently, we do not log browsing histories, traffic data, or IP addresses utilized for internet access through our services. As a result, we are unable to establish a connection between shared IP addresses of VPN services and individual users, or otherwise identify individual users based on data that is not processed by us. Consequently, even if we were to receive a legally justified request, it might prove unfeasible for us to ascertain a specific person or provide any identifying information pertaining to that individual.

In cases where, following an appropriate legal process, we are mandated to comply with a request, we will provide the limited data we process as outlined in our Privacy Policy, to the extent that it aligns with the scope of the request.

For contact information regarding government authorities:
VEEPN, Corp
Samuel Lewis Ave & 55th Street, PH SL55 Building, 21st Floor, Panama, Republic of Panama
email: [email protected]

For now we did not receive any request from government agencies to provide any information related to the use of our services.

The changes will appear in the Warrant Canary if such requests come.

How you can access your information

Requests

If you would like to update or correct any information that you have provided to us through your use of the Service, you may use the Service to do so. If you need help with the changing of data you think is inaccurate, please contact us via email at [email protected].

Requests to erase your Personal Information. If you reside in the European Union or California, you can request to erase your Personal Information via [email protected]. Please note that it may affect the Services provided, and you will not be able to use their full scope. Please also note that the erasing of your Personal Information does not mean the automatic cancellation of your subscription or refund of your payments.
Request to receive the Personal Information related to you. If you reside in the European Union or California, you can request to receive Personal Information related to you via [email protected]. In case you make such a request, you will be required to provide us with an email address, to which we will be able to send your Personal Information. Please note that you’ll have to confirm and guarantee that the email address you provide to us to receive your Personal Information belongs to you and you are solely responsible for its correctness and validity; therefore, we are in any case not liable for any breach of your Personal Information due to sending it to that email address.
Objection to the processing of Personal Information concerning you. If you reside in the European Union, you may object to the processing of Personal Information concerning you for direct marketing purposes by contacting us at [email protected]. The applicable Personal Information, if any, will no longer be processed for such purposes.

VeePN prioritizes user privacy worldwide by collecting minimal data and empowering users to control their personal information. The General Data Protection Regulation (GDPR) of the European Union (EU) requires us to outline those practices in a specific manner for users in the EU.

In line with the GDPR, we collect and process the data outlined in this Privacy Policy on one of the following bases, depending on the circumstances:

For the purposes of fulfilling our contractual obligations to users, including:
- Providing users with the Services and Apps they have requested
- Managing user subscriptions and processing payments
- Providing customer support
For a legitimate interest associated with the operation of our business, including:
- Enhancing the quality, reliability, and effectiveness of our Site, Services, and Apps
- Communicating with customers to provide information and seek feedback related to our Services and Apps
With the consent of users, that users can withdraw at any time.

You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at [email protected].

Opting out via your device

Please note that you may also opt-out from the collection of your data for marketing and advertising purposes not only via our Application but also on your entire device using your device settings.

How do we secure the information

We place great importance on the security of all personally identifiable information associated with our users. We have security measures (including physical, electronic, and procedural measures) to help safeguard your Personal Information from unauthorized access and disclosure.

Namely, VeePN has no access to your database password or any data stored in your local database on your devices. If you are using VeePN data records or tasks synchronization and backup service, VeePN will have access to the encrypted binary file on our servers which contains your database. We need this access to provide you with a secure backup and restore of your local personal database in case you have lost or damaged your device. VeePN will have no access to the data stored in this database.

Please note that we do not store the monitored data regarding the potential exposure of your credentials when using the VeePN Breach Alert. However, you have the option to save this information on our platform for further monitoring purposes.

As it was previously mentioned, VeePN does NOT collect either logs or any user activities while using any of their VPN services. VeePN stores the encrypted information about the number of connected devices for each account, as the maximum permitted amount is limited. This information can be assessed in the VeePN account, where any user can delete their devices from their account.

While we cannot ensure or guarantee that loss, misuse, or alteration of information will never occur, we make all reasonable efforts to prevent it. However, you should bear in mind that the submission of information over the Internet is never entirely secure.

Links to other services

There might be several places on our Service where you may click on a link directing you away from our Service to access other applications or websites that do not operate under this Privacy Policy. These third-party websites may independently solicit and collect information, including Personal Information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

Consent and age restrictions

Our Services are not intended for anyone under the age of 18. We do not knowingly collect personal information from persons under 18 years old. If we become aware that we have inadvertently obtained personal information from a person under 18, we will promptly delete such information from our records and terminate such account, if applicable.

If you are a parent or legal guardian and have reason to believe that your child under the age of 18 has provided us with personal information, please contact us immediately so that we can take appropriate measures to remove the information and protect your child's privacy.

Retention

We will keep your information for as long as the Application is installed on your mobile device or as needed to provide you with our Service. If you remove the Application, we will remove your information and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to this privacy policy

We may update our Privacy Policy from time to time. That is why we advise checking our Service occasionally to be informed of any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. The usage of the Application by you after changes have been posted to the Privacy Policy will denote your acceptance of such changes.

How to contact us

Please submit any questions, concerns, or comments you have about this Privacy Policy or any requests concerning your Personal Information via email at [email protected].

California resident notice

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.

DATA SHARING. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CALIFORNIA PRIVACY RIGHTS.

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. Please, note that we shall not be required to provide personal information to you more than twice in a 12-month period.
The right to prohibit sale of information means that you have the right to request that we stop the processing of your data for direct marketing purposes either by asking us to cease processing all data about you or asking us not to send you direct marketing communications. We generally do not sell your Personal Information for profit.
The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
The right to opt out of automated decision-making technologies means your right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
The right to restrict the use of your sensitive information means directly contacting us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. Please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information if we need it to, among other things: (a) complete the transaction for which the personal information was collected, or (b) fulfill the terms of a written warranty or product recall; (c) detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (d) debug to identify and repair errors that impair existing intended functionality; (e) comply with the California Electronic Communications Privacy Act; (f) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (g) comply with a legal obligation.
Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
The rights to portability means your right to receive your personal information in an electronic and structured form to you or to another party.

SALE OF DATA. We do not sell any of your personal data to third parties.

Colorado resident notice

This section applies only to Colorado residents in addition to the rest of this Privacy Policy. We process personal data in compliance with the Colorado Privacy Act that requires us to disclose the following additional information related to our privacy practices.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will provide you with the required information in an alternative format that you can access.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

COLORADO PRIVACY RIGHTS.

The right of access means the right to know if a controller is processing the consumer’s data.
The right to portability provides the ability for you to receive the data in their right to access in a portable and machine-readable format, where technically feasible, that enables you to transmit the data to another entity without hindrance. Please note that you may only exercise the right to data portability twice per calendar year.
The right to opt-out means your right to object to the processing of your personal data for such purposes as (1) the sale of your personal data. Please note that we do not sell any of your personal data to third parties; (2) Targeted advertising, or (3) Profiling to help make decisions that produce legal or similarly notable effects concerning a consumer.
The right of correction means your right to request that we rectify inaccurate information about you.
The right of deletion means that you can ask us to delete or stop processing your personal data.
The right of appeal means that if you are not satisfied with resolving your privacy request, you can initiate an appeal procedure described below.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts. If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee. If we refuse to take action on your request, you can follow the appeal procedure within 30 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

Virginia resident notice

The following section pertains exclusively to residents of Virginia. It outlines our practices regarding the collection, utilization, and sharing of Personal Data belonging to Virginia residents, in our capacity as a business operating under the Virginia Consumer Data Protection Act ("VCDPA"). Additionally, it outlines your rights in relation to your Personal Data. Please note that the term "Personal Data" used in this section holds the definition ascribed to it by the VCDPA, with the exception of information exempted from the VCDPA's scope.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

VIRGINIA PRIVACY RIGHTS. As a resident of Virginia, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

Correct inaccuracies in the consumer’s personal data that is collected by the controller.
Confirm if the controller is actually processing their personal data or request a copy of the personal data.
Delete personal data provided by or obtained about the consumer.
Obtain copies of the personal data collected by the controller.
Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
The right to restrict processing of your sensitive personal information. We do not process any sensitive personal information to infer characteristics about you.
You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.
Appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts. If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee. If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected]. adding in the subject of email “Appeal to answer on privacy request”. We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

SALE OF DATA. We do not sell any of your personal data to third parties.

Connecticut resident notice

This notice outlines the manner in which we, acting as a "Controller" under Connecticut's Data Protection Act ("CTDPA"), collect, utilize, and disclose your personal data, as well as the rights you have concerning your personal data, including sensitive personal data. In this context, "personal data" and "sensitive data" carry the definitions provided in the CTDPA and do not encompass information excluded from the scope of the CTDPA.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. Before processing most requests, we will need to verify your identity and confirm that you are a resident of the State of Connecticut. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. If you are submitting a request on behalf of a Connecticut resident, including a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal data, and that you are authorized to submit the request on their behalf. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CONNECTICUT PRIVACY RIGHTS. As a resident of Connecticut, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

Right to know. You have the right to verify whether we are processing your personal data or not.
Right to deletion. You have the right to request the deletion of your personal data under certain circumstances. If you make such a request, we will assess whether we are legally obligated to comply or if there are reasons that limit the scope of the deletion. If there are any reasons, we will provide you with an explanation in our response.
Right to access. The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.
The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
The right to ppt out of profiling. You have the right to choose not to have your personal data processed for profiling purposes that could lead to decisions with significant legal or similar effects on you. If you wish to exercise this right, you can opt out of such profiling activities.
The right to appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

Last updated: March 10, 2025