Privacy Policy

This document ("Privacy Policy") explains the privacy rules applicable to personal data and other information collected or submitted when you access, install, or use Zen7VPN Services and Websites regardless of the device (computer, mobile phone, tablet, etc.) you use. By visiting our Websites, 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 Websites.

1. PROCESSING OF YOUR PERSONAL DATA

Zen7VPN processes personal data to a limited scope to provide Services, process payments for the Services, and enable the functioning of our Websites and mobile applications. We may process the following categories of personal data:

Information for creating your Account

  1. Email address.We ask for your email address as part of your registration. It is necessary for the creation of your Zen7VPN Account, retrieving a lost password, and using the Services.

Subscription information

  1. 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.).

Payment related information

  1. Payment data.This information is necessary to collect payments for the Services. Our payment processing partners process basic billing information for payment processing and refund requests (e.g., date of purchase, payer’s IP address, postal (ZIP) code, credit card owner's full name and credit card information). We also process some of such billing information ourselves (e. g., date of purchase, credit card owner's full name, part of your credit card number, its expiration date) in cases of recurring payments or when you provide your payment details directly to us.
  2. Country details.When making a purchase we process information on the user’s country the purchase takes place from. This information is necessary for VAT calculation purposes.
  3. Information for payment fraud prevention.To prevent fraudulent payments for the Services, your personal data (such as payer's email address and device information) can be verified by our and/or our payment processing partners fraud management tools. A payment transaction that is considered high risk may be rejected by us.

Communication data

  1. Email address.We use your email address to: i) send you important updates and announcements related to your use of the Services and Websites; 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).
  2. 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.
  3. 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.
  4. Chatbot.If you contact us via our chatbot on our Websites, in addition to processing your contact information, we will be able to collect your device information and IP address.
  5. Live chat widget.If you contact us via live chat widget, in addition to processing your contact information, we will also process your device information (such as type of the operating system and browser) and IP address. This information is necessary for our support to determine the user's country, prevent abuse,see if the user is connected to our servers, and help our support to process queries faster.

Information collected on our applications and Websites

  1. Features usage.We collect information about Zen7VPN features you use.
  2. Access logs.As most websites on the internet, our Websites 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.
  3. Cookies.Cookies, pixels, and other similar technologies are usually small text or image files that are placed on your device when you visit our Websites. Some cookies are essential for our Websites to operate smoothly; others are used to improve Websites’ functionality, analyze aggregated usage statistics to improve Websites’ performance, and for advertising. We also use affiliate cookies to identify the customers referred to our Websites by our partners so that we can grant the referrers their commission.

Referrals data

  1. Information for participating in referral programs.Participation in referral programs maintained by Zen7VPN requires referrers to submit personal data (e.g., full name, e-mail address, phone number, relationship with the referred party) about themselves and a referred party so that Zen7VPN could i) reach out to the referred party; ii) contact referrers with regards to their participation in referral programs and/or provision of rewards. It is the referrer's responsibility to abide by applicable privacy laws when disclosing third parties’ personal data to Zen7VPN, including informing third parties that they are providing referred parties’ personal data to Zen7VPN and how it will be used and processed. Referred parties may unsubscribe from any future communication at any time. If you believe that one of your contacts has provided us with your personal data and you would like it to be removed from our database, please contact us.

Promotional games data

  1. Information for participating in our promotional games (e.g., sweepstakes, giveaways, contests).When you decide to participate in any promotional game that requires additional personal information, you will be explicitly requested to provide it. The personal data we ask you to provide typically includes your full name, e-mail address, phone number, information about the purchased subscription plan. However, you have the right to refuse to provide such information and cease your participation in the promotional game at any time. In certain cases we also may share the mentioned data with third parties that help us to organize/coordinate such promotional games. Please carefully review the terms and conditions of each promotional game in which you participate as they may contain specific additional information about the processing of your personal data. If the terms and conditions of such promotional games concerning the treatment of your personal data conflict with this Privacy Policy, the terms and conditions of such promotional games shall prevail.

Social networks data

  1. Account data.For the purpose of managing and administering our profiles on social networks (e.g., “Facebook”, “Instagram”, “Twitter”, “LinkedIn”, “YouTube” accounts), we may collect and process your personal data (e.g., full name, social network profile name, pictures, and/or public comments) you provided voluntarily.

2. GROUNDS FOR PROCESSING OF PERSONAL DATA

Your personal data is processed:

  1. 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 Websites.
  2. 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).
  3. 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 Zen7VPN’s contests, offers, referrals, or promotions. Please note that although Zen7VPN 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.
  4. 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 Websites; iii) to protect against harm to the rights, property, and safety of Zen7VPN, 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 Websites and applications are being used (crash reports, app store reviews, information about the channel from which our app was downloaded, etc.).

3. 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:

  1. Delete: request us to erase your personal data;
  2. Access: know and access personal data Zen7VPN has collected about you;
  3. Rectify: rectify, correct, update, or complement inaccurate/incomplete personal data Zen7VPN has about you;
  4. Object: object to the processing of your personal data which is done on the basis of our legitimate interests (e.g., for marketing purposes);
  5. 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);
  6. Restrict: restrict the processing of your personal data (when there is a legal basis for that);
  7. Withdraw consent: withdraw your consent where processing is based on a consent you have previously provided;
  8. Lodge a complaint: exercise your rights by contacting us directly or, if all else fails, by lodging a complaint with a supervisory authority.

4. CHILDREN’S DATA

Zen7VPN 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 Zen7VPN. 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.