PRIVACY POLICY

1. Personal Data We Collect

"Personal data" refers to any information that identifies, relates to, or could reasonably be linked to a specific individual (excluding data that is anonymized, de-identified, or otherwise not considered personal). We collect the following types of personal data for business and commercial purposes:

Data You Provide Directly

You may provide personal data when you:

• Register an account on our website or applications
• Sign contracts with us
• Enroll in our events or use our Services
• Interact with us on social media or through other channels

The personal data you provide may include:

• Name, business name, email address, physical address, phone number
• Profile details, usage and performance information
• Payment or billing data, and in certain cases, a government-issued ID or tax-related documentation

Data Obtained from Third Parties, Affiliates, and Subsidiaries

We may receive personal data from our business partners, affiliates, and subsidiaries to update or enhance our records, explore potential business relationships, or serve more relevant ads. This data may include contact details, professional or social media profiles, commercial information, and preference inferences.

Data Collected Automatically

When you use our Services, we may automatically gather certain technical information for business or commercial reasons, including:

• System and Hardware Information: Device ID, device type, network details, time zone, operating system version, order printing logs, location (based on device ID), IP address, and other general system metrics
• Cookies: We use cookies, web beacons, and similar tracking technologies to analyze and improve our Services. For additional details, please refer to our Cookies Policy.

2. How We Use Personal Data

Our principal objective in collecting personal data is to fulfill your requests for our Services or related information. Where required by law, we seek your consent in advance. Otherwise, we rely on other valid legal grounds (like contractual obligations or legitimate interests). We use personal data for the following:

Providing Requested Services or Information

If you submit personal data through our platforms, we may use it to respond to your inquiries or deliver relevant product and service updates. We also send administrative messages, such as policy changes or important notices.

Managing User Registration

If you register an account with us, we process your personal data for business purposes, including account administration and fulfilling any contract you have with us.

Communications and Marketing

With your permission, or if allowed by law, we may:

• Send product announcements, newsletters, and industry updates we believe you may find relevant
• Engage in telemarketing or promotional outreach, based on our legitimate interests

Payment Processing

If you provide financial details (e.g., credit card information), we will verify and process such data as needed to fulfill payment obligations associated with your contract or transactions with us.

Event Organization and Execution

When you sign up or participate in our events, we may:

• Use your data for event registration and billing
• Connect you with other attendees or third-party vendors involved in the event
• Follow up with details on future events or services you might be interested in

Security, Legal Compliance, and Investigations

We may process personal data to:

• Detect, investigate, and prevent fraud, security threats, or unlawful conduct
• Comply with laws, regulations, and legal processes
• Protect our rights and those of affiliates or third parties
• Facilitate business transactions (e.g., mergers, acquisitions, asset sales, or reorganizations)

Improvements and Enhancements

We use personal data for legitimate interests to diagnose technical issues, analyze usage trends, and roll out new or improved offerings. Customer feedback and suggestions often guide our product roadmaps and updates.

Personalizing Your Experience

To deliver tailored content and advertising, we and our service providers may use site-tracking technologies to evaluate user preferences and serve customized content, including ads on external websites or platforms.

3. How We Share Personal Data

Affiliates and Service Providers

Like most companies, we share personal data with our affiliates and trusted third-party vendors who perform tasks on our behalf, such as IT support, data analytics, email distribution, or campaign management.

Advertisers

We may share personal data with advertising partners so they can display ads in our Services or promote our offerings on third-party websites.

Law Enforcement

We may disclose personal data if we reasonably suspect unlawful activity or believe such information could assist in investigations. If you violate our policies or if sharing data is necessary to safeguard the rights, property, or personal safety of us or third parties, we may also share personal data with law enforcement agencies.

Legal Proceedings

We will share personal data when lawfully required (e.g., in response to subpoenas or court orders) or to protect our legal rights, including defending against legal claims.

Business Transfers

In events such as a merger, acquisition, sale of assets, reorganization, or similar transaction, personal data may be transferred to involved parties. We will make reasonable efforts to notify you if your data is transferred to a non-affiliated entity.

Consent

With your explicit consent, we may share your personal data with specific third parties for mutually agreed purposes.

4. Your Data Protection Rights

Scope of Your Rights

Depending on applicable privacy laws, you may have the right to:

• Request access to or copies of personal data we hold about you
• Request that we limit or object to certain processing activities
• Request that we correct or delete your personal data

Please note, these rights are not absolute and may vary based on specific legal exceptions. We may need to verify your identity or request additional details before processing your inquiry.

How to Exercise Your Rights

If you wish to exercise these rights, please email us at:
support@vinevpn.com

Should you be unsatisfied with our response, you may file a complaint with the appropriate regulatory body in your jurisdiction.

5. Cross-Border Data Transfers

We may store and process your personal data in the United States and other regions where our affiliates, subsidiaries, or service providers have operations. By providing personal data to us, you acknowledge that it may be transferred to and processed in other countries. We adhere to the relevant data protection laws when conducting these transfers, which can include the use of EU Standard Contractual Clauses. For inquiries, please contact us at:
support@vinevpn.com

6. Data Retention

We keep personal data only for as long as is necessary or legally permitted under the purposes outlined in this Privacy Policy. The main factors influencing retention include:

• The ongoing nature of our relationship with you and the duration for which we provide you with Services
• Applicable legal obligations (e.g., certain tax or financial recordkeeping)
• Whether retaining data is necessary for our legal position or a potential dispute

7. Security Measures

We have implemented technical and physical safeguards to help protect personal data. However, no method of data storage or transmission over the internet is entirely secure. Please exercise caution when sending information online, recognizing that it may be viewed or used by unauthorized parties. All communications with us via the internet or other means are taken at your own risk.

8. Additional Provisions

Third-Party Sites and Apps: Our Privacy Policy does not extend to any third-party websites or applications—even if they appear within our website (e.g., payment solutions or delivery platforms). We encourage you to review each third-party's privacy policy before sharing any personal data with them.

Minors: Our Services are not directed to individuals under 16, and we do not knowingly collect personal data from children under that age.

Policy Updates: We may revise this Privacy Policy at any time. Please check back periodically to stay informed of any changes. We will indicate the policy's latest effective date at the bottom.

9. Contact Us

10. California-Specific Clauses

This section outlines additional rights and obligations under the California Consumer Privacy Act (CCPA) and related laws, applicable to California residents:

Information We Collect, Use, and Disclose

Over the last 12 months, we may have collected the following categories of personal data:

• Identifiers: Information such as name, company name, email, address, and phone number (either provided by you or obtained from third parties)
• Personal Records (Cal. Civ. Code §1798.80(e)): Contact data including address, phone number, or other details
• Commercial Information: Cookies, transaction logs, and social media or professional data
• Internet or Other Electronic Network Activity: Data from cookies, system usage, and additional relevant information from third parties
• Professional or Employment-Related Data: Details about your company, employees, or contractors
• Inferences: Derived insights on individual or business preferences
• Financial Data: Payment details and possibly a government-issued ID or tax identifiers

For more information, see "Personal Data We Collect" and "How We Share Personal Data."

Your Rights Under CCPA

• Right to Know and Data Portability: You can request that we disclose how your personal data was collected, used, disclosed, and potentially "sold" (as defined by the CCPA) over the previous 12 months.
• Right to Delete: Subject to certain legal exceptions, you may request that we delete personal data we have collected and retained about you.
• How to Exercise These Rights: Refer to "Your Data Protection Rights." We will need to verify your identity prior to processing your request. You may submit up to two verifiable consumer requests within a 12-month window.
• Non-Discrimination: We will not treat you differently for exercising your CCPA rights. However, we may offer incentives tied to the value of your personal data, subject to your informed consent, which you may withdraw at any time.
• Sale of Personal Data: We do not "sell" personal data in the conventional sense. If we ever use or allow advertising cookies, we do so with your consent.
• "Shine the Light": Under California Civil Code Sections 1798.83-1798.84, California residents may request specific details about data shared with third parties for direct marketing purposes.
• Do Not Track: Some browsers and devices allow you to send "Do Not Track" signals. At this time, we do not alter our practices based on such signals.

If we need to contact you regarding a data breach or any other security matter relating to your personal data, we may do so by email, phone, mail, or other methods as legally required.