Last updated: 29/09/2022
1. How CometVPN Gathers and Stores Users’ Personal Data
As an online VPN service provider, CometVPN strives to gather the minimum amount of data necessary to ensure the Service’s operation. CometVPN is focused on privacy and does not process any information related to the Users’ online activity. CometVPN does not collect any information on what Users do online (IP addresses the User communicates with, session information, browsing history, used bandwidth, network traffic, session length, or any similar information.) The Service does store information about the User’s connection to a specific VPN server (User ID and session length), but this data is deleted automatically within 9 months after the session ends.
1.1 Account User Data
When a User creates a new CometVPN account or updates an existing account, the Service collects and stores this information as it is necessary for the Service to run adequately.
|How we use it
|Your email address
|Communication, marketing, product news, purchase confirmation, and receipts
|Confirmation that the email address provided by the User is valid and belongs to the User
1.2 Operational Data
CometVPN also collects and stores what we call operational information. This data is necessary to ensure the Service’s operation and is gathered when a User connects to the Service. This data includes the User’s operating system version, CometVPN application version, the total amount of data used, and other operational information (payments made, Service upgrades or downgrades, referrals, participation in special offers).
1.3 User Data Collected on Payments
CometVPN accepts payments through our partners - Paddle and Coingate. When a User makes a purchase using any available payment methods, it will result in a data exchange with our partners.
When the User pays for the Service with a credit card, CometVPN stores the following data:
This data is used exclusively for credit card fraud prevention. CometVPN never stores the User’s full credit card number or location at the time of purchase. To maintain the safety of payment information, CometVPN adopts all available security measures (like multi-factor authentication) available from the payment partners.
1.4 Other Data CometVPN Doesn’t Gather
To make things clear, CometVPN does not gather, log, or store the following information:
Any personal information the User shares with CometVPN will be handled in accordance with the following principles:
2.2 Sharing Personal Information With Third Parties
CometVPN will not share any of the User’s personal information with other commercial parties under any circumstances except as described below.
CometVPN may send data to third parties that aid the Service in terms of customer support, hosting, emailing, securing the Service’s infrastructure, DDoS prevention, payment processing, Website analytics, and Service usage analytics.
In case CometVPN is served with a legally binding subpoena, warrant, or any other legal document and the law urges CometVPN to comply, the extent of disclosure is limited to personal information listed in this privacy notice.
In case CometVPN’s organizational structure changes (due to restructuring or acquisition), the Service might migrate the User’s personal information to a third party. However, CometVPN will ensure that such a third party enters an agreement under which the use of the User’s personal information only relates to purposes necessary for the transaction.
CometVPN doesn’t store the User’s IP address when connected to the Service and can’t identify Users based on this data. In addition, CometVPN cannot share information about the User’s activity (applications, websites, services, IP addresses, or any similar information) as the Service does not store this information.
2.3 User Consent and Interest
The User reserves the right to decline contact from CometVPN.
2.4 Limiting Data Gathering
CometVPN takes great care not to gather personal information indiscriminately. Gathering personal information is limited to the minimum necessary to operate the Service.
2.5 Limiting Information Use, Retention, and Disclosure
CometVPN will not use the User’s personal information for any purpose the User did not consent to. CometVPN will never sell or trade personal information for monetary gain or any commercial purposes.
CometVPN’s employees will be granted access to personal information on a need-to-know basis. A condition of employment for all these employees is to respect the confidentiality of this personal information.
CometVPN stores personal information strictly as necessary for the purposes this information is collected - to ensure uninterrupted Service operation, pursue legitimate business purposes, resolve disputes, organize legal defenses, enforce agreements, and comply with any applicable laws. CometVPN will erase any records containing personal information once they’re no longer required. This procedure will be performed in a way that ensures the User’s privacy.
2.6 Privacy Protection
CometVPN utilizes the strongest available measures to protect its records, including the User’s personal information. CometVPN implements the most advanced physical, technical, and business security measures designed to prevent any unauthorized access, theft, loss, disclosure, copying, modification, or use of the User’s personal information.
2.7 User Access
If the User has any questions regarding CometVPN’s records which contain the User’s personal information, CometVPN will try its best to answer them. The User reserves the right to be informed about the User’s personal information CometVPN maintains and how that information is used. CometVPN will provide the User with the information on the existence, use, and disclosure of the User’s personal data upon request.
2.8 Right of Access, Erasure, Rectification and Restriction
The User reserves the right to inquire about how CometVPN is processing the User’s personal information, request access to this information, and request CometVPN to delete, correct, or amend this personal information in case it’s inaccurate.
Contact us at [email protected] to seek rectification, request access, or request erasure of your personal information CometVPN has gathered.
CometVPN requires each User to log in to their account with a valid email and a password before gaining access or being allowed to make any changes to the User’s personal information.
As a sign of good faith, CometVPN provides each User with the ability to erase their personal information. However, CometVPN may not be able to comply with this request in certain situations, including but not limited to:
In case CometVPN determines that there is no way to erase the User’s personal information, CometVPN will provide an explanation and contact information for any further inquiries.
In case you’re not satisfied by how CometVPN addressed your complaints or concerns, you can contact [email protected] for further guidance at: Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, Republic of Panama, https://cometvpn.com.