Privacy Policy

1. Parties

This is the FirstVPN’s (“we”, or “our”) Privacy Policy. This Privacy Policy discusses the ways in which we collect, use, maintain and disclose information collected by us from our customers, visitors to our Web-Sites, and, in some cases, visitors to our customer’s web-sites (“Users”). Capitalized terms used but not defined in this policy have the meaning given to them in our Terms of Use.

2. Acceptance of the Policy

You accept this Privacy Policy by using our Web-Sites (referred to herein as the “Site”), placing an order for Services (as defined in the Terms of Use) with us or joining our email list. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE SERVICES IMMEDIATELY.

3. Legal Basis for Data Processing

The General Data Protection Regulation (GDPR) provides various legal bases on which personal data can be legally processed. We base the processing of your data on the following legal principles:

• Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR)
• the initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR)
• the fulfilment of a legal obligation (Art. 6 para. 1 lit. c) GDPR

4. Security

We have implemented technical, physical and administrative safeguards designed to protect personal information against loss and against unauthorized access, use, and disclosure. Passwords are stored on our server in encrypted form. We have personal information retention processes designed to retain personal information as necessary for the purposes stated above or to otherwise meet legal requirements. Unless this Privacy Policy states otherwise, our employees are required to keep the information set out here confidential.

5. Information that we collect

Users who are our customers provide us with their name, address, personal ID number, phone number, credit/debit card or bank information and other personally identifiable or confidential information and other information we require to provide Service to them. Please, notice that the type of information that we collect differs whether you are an individual customer, or you are a company representative. We may also acquire information about customers from third parties such as credit reporting agencies, as well as collect information about our customers’ use of the Services.

We do not sell any personal information. We may disclose personal information to other trusted third party service providers or partners for the purposes of providing you with the Services, storage and analytics and to comply with our legal requirements and internal guidelines. We may also transfer or disclose personal information to our subsidiaries, affiliated companies.

6. Using your personal information

We use your information in order to provide you with the Service and to comply with our legal requirements and internal guidelines. This means that we will use the information to set up your account, provide you with support regarding the Service, communicate with you for updates, marketing offers or concerns you may have and conduct statistical and analytical research to improve the Service.

7. Storage period

We store your data,

• if you have consented to the processing at most until you revoke your consent;
• if we need the data for the execution of a contract, at the most as long as the contractual relationship with you exists or legal retention periods run;
• if we use the data on the basis of a justified interest, at the most as long as your interest in deletion or anonymization does not prevail;
• if legal (e.g. commercial code, tax code) exist, until the end of these storage obligations.

8. Customers’ rights to collecting data

With respect to your personal data you have the following additional rights granted by the General Data Protection Regulation (GDPR):

• to get familiar with your personal data and how it is processed;
• to demand restricting the processing of your personal data when personal data is processed without complying with legal requirements or when there is another legal basis;
• to demand to transfer your personal data to another data controller or provide it directly to you in a convenient format (applicable to that personal data that you submitted and that is processed by automated means on the basis of your consent);
• to object to processing of your personal data, if it is processed on the basis of a legitimate interest, unless there are legitimate reasons for such processing or for the purpose of making, pursuing or defending legal claims;
• in cases where your personal data is processed on a separate consent basis, you have the right at any time to withdraw your consent to processing of your personal data;
• if you think that your data is processed unlawfully or your rights in connection with data processing are violated, you have a right to contact a relevant data protection authority of your habitual residence, place of work or of an alleged infringement and file a complaint. We recommend you to contact us before submitting a formal complaint in order to find the right solution to a problem.

9. Deleting personal information

You may request that we delete your personal information, and we shall attempt to accommodate such requests. However, we may retain and use personal information for such periods of time as required or permitted by law or best business practices.

10. Changes to the policy

If we make any significant changes to this Policy we will notify you by email, post a notice of such changes on the Site or flag our Privacy Policy on the Site as updated. You agree to our use of electronic communications with you for purposes of this Policy. If you do not agree to the changes to this Policy, we will continue to maintain and use personal information previously collected in accordance with the Policy in force as of that date.