Turnswitch Media Limited (throughout this Notice we will refer to Turnswitch Media Limited as "we", "us" or "our") operates a variety of websites ("Websites" or "Sites") including www.mysmartvpn.net and is committed to protecting the privacy of our Website users ("Users") and Our members ("Members").
About This Privacy Notice
This privacy notice (the "Notice") advises how we collect and process information that may identify you (“Personal Information”) when you use our sites, sign in as a user, buy products or Services, or interact with us in other ways. We may show you other privacy notices when we collect or share your personal data and this privacy notice is in addition to those.
It also explains how we may collect, store, use or otherwise process your Personal Information. We respect your privacy and will take reasonable steps to protect your Personal Information in accordance with this Notice and applicable laws.
This Notice will explain:
- the type of information we may collect about you;
- how we will use the information we collect;
- when we may use your details to contact you;
- how and when we may disclose your details to a third party;
- the rights you may have in relation to your information.
Our Websites may contain hyperlinks to third party websites which are not owned or operated by Us. We urge you to review those policies as we are not responsible for any information collected about you from websites which we do not own or operate. Your use of such websites is at your own risk.
Changes to This Privacy Notice
This Notice was last updated on 7 January 2020. We reserve the right to make changes to this Notice at our discretion. If we do make any changes, this page will be updated. We therefore recommend that you review this page periodically so that you are aware of any changes.
If you have any questions regarding this Notice, please visit www.mysmartvpn.net select 'Contact Us' and complete the contact form or contact us at firstname.lastname@example.org.
As you visit our Sites and use our Services, we may collect the following information about you:
- Direct Identifying Information: This may include your name, address, email address, username and password.
- Indirect Identifying Information: We automatically receive and record certain information from your device or web browser when you interact with our Sites, e.g. your internet protocol (IP) address, mobile device ID, time zone setting, location data, language preference, operating system and platform. We may also create a user ID that may similarly indirectly identify you.
- Location Data: To assist with our analytics and to provide a tailored service for you, we may collect geo-data which tells us where you are. We may also collect the language option or country you choose. We may link location data to other information we have collected about you.
- Profile Data: This data may include your name, address, e-mail address, username, password and other information you give us when registering for our Services.
- Marketing and Communications Data: This may include information about your subscriptions to newsletters and your marketing preferences.
- Financial Data: We will need to collect your credit card details when you register for our Services or make purchases on our Site.
All data collected will be securely and safely stored on servers specific for this purpose.
The Collection of Information
We may collect information from you in the following ways:
- Information You Provide Us: This information includes information you provide on registration: your name, e-mail address, date of birth, gender, credit card information, billing address, SIP code and/or postcode and other information (“Personal Information”). We may also collect information if you participate in a survey, promotion, competition or sweepstakes, if you contact us through our customer support team or if you adjust the preferences in Your Account.
- Information We Collect Automatically: Information is collected when you use our Services. This may include, but is not limited to, information about the device you use to access our Services, your IP address, browser and software features, referral URLs, crash reports and your activities and use of our Service e.g. which games you play.
The Use of Other Tracking Mechanisms
Our Site may use technology such as web beacons, web bugs or clear GIFs to track and analyse non-personally identifiable usage information and to compile statistical information about our Users (e.g. their IP address, browser type, internet service provider etc.) in order to improve the Site's quality and to support our business.
You should note that We also use HTML5 localStorage technology to enhance your user experience. This technology operates in the same fashion as cookies technology and therefore we will use this mechanism to collect and store information as well as configure your experience in the same ways outlined above.
The Use of Information We Collect
We will use your Personal Information to help cater and deliver to you a unique User experience. We may use your information in the following ways:
- to provide our Services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
- to improve our Services;
- to provide you with the most user-friendly online experience;
- to use IP addresses and device identifiers to: identify the location of users, block disruptive use, establish the number of visits from different countries and other statistical purposes;
THE USE OF YOUR PERSONAL INFORMATION
We will use your Personal Information for our internal business purposes e.g. to:
- monitor, develop and improve the Services and/or your experience based on a monitoring of your preferences and behaviours;
- administer the provision of your Services;
- process payments and/or collections;
- process and deal with any complaints or enquiries made by or about you;
- investigate any suspected breach of our Terms and Conditions or the breach of other terms and conditions otherwise relating to you;
- investigate any suspected fraud occurring on your account;
- contact you if you are the lucky winner of a sweepstakes or competition;
The Collection, Use and Handling of Children’s Information
In accordance with our Terms and Conditions, only individuals 18 years and over may use our Site and Services. If you are aware or become aware of any person under the age of 18 using our Services, please contact us immediately and, unless permission is obtained from their parent and/or guardian and/or the bill payer, we will take steps to delete their account and all Personal Information. We are committed to protecting children's privacy on the Internet and we comply fully with the Children's Online Privacy Protection Act (COPPA).
Where appropriate, we will instruct children not to provide such information to us. If a parent becomes aware that a child has provided us with Personal Information, we ask that the parent or legal guardian of the child contact us by visiting www.mysmartvpn.net, selecting 'Contact Us'.
Generally, we will only send you marketing e-mails if you consent to us doing so. If you do subscribe to our marketing e-mail service, we may periodically contact you to tell you about any additional services, special offers and upcoming promotions or events offered by Us, our subsidiaries, our affiliates or our marketing partners that we think may be of interest to you ("Direct Marketing"). You can unsubscribe from this part of our Service at any time.
Sharing of Personal Information
We will never sell your Personal Information. We may, however, share your Personal Information in the following ways:
- Your Public Postings: If you post a review or make a comment anywhere on our Site or platform and your post contains your Personal Information, those details may be shared with other Users to have access to that particular part of our Service.
- Sharing with Third Party Providers: We may need to use third party service providers to provide the best possible Services to you. At times, we may need to employ external vendors, service providers and suppliers to assist us with e.g. processing credit card payments, fraud scoring and prevention, debt collection and telecommunications. These third parties may need access to your Personal Information as is reasonably necessary to perform their obligations; they are not permitted to use your Personal Information for any other reason.
- Sharing with Affiliate Companies: Where you permit us to, We, our affiliates and subsidiaries (where We have granted permission) may disclose to their affiliates and business partners certain Personal Information and other details of the use of our Services so our partners can send you their own Direct Marketing communications. If you do not want us to disclose your Personal Information to our affiliates or business partners for Direct Marketing purposes, you may opt out by (a) checking the appropriate "Opt Out" box in any applicable e-mail communication or e-newsletter, (b) visiting www.mysmartvpn.net, selecting 'Contact Us'.
- Third Party Features: We may, at times, include on our Sites additional features and functionality from third parties. Some of these features may require us to send selected information about your use of our Service (e.g. content viewed) to third parties. If you do not wish for Us to share this information, you may opt out. We will never send your password or your financial information to any third party through these features or functions.
- Cleaned Data: Periodically, we take steps to "clean" Personal Information provided to us, e.g. we may remove information which can be used to identify individuals anonymising, pseudonymising, summarising, aggregating or removing certain data elements. The resulting cleaned data is no longer considered personal information and is not subject to this Privacy Notice. The cleaned data may be provided to various third parties as necessary to provide you with our Services.
- Business Restructuring: If We undergo a reorganisation or restructuring we may need to share your Personal Information within our group of companies so we can continue to deliver our Services to you without interruption. We may also share your information to a third party if we participate in a merger, acquisition, reorganisation, restructure or other sale of some or all of our assets. You should however note that if, due to a reorganisation or restructure, we become subject to a new owner, your information may be subject to the new owner’s Notice. In these circumstances, you will be notified by e-mail or through an update of this Notice prior to the change.
- Legal Necessity: Where permitted or required by any law or regulation we may collect, use or disclose your Personal Information or other information without your consent, e.g. in response to a court order or subpoena or to comply with a legally permitted inquiry by a government agency. We may also share your information to detect, prevent, or otherwise address fraud, security, or technical issues.
Be assured that, whilst we may share your information as indicated above, your Personal Information and other information will remain subject to and will be governed by this Notice at all times.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We take the protection of your Personal Information seriously and we endeavour to take all reasonable measures to protect any information we collect, use, store or disclose. Where possible we have implemented technological and organisational procedures designed to protect the integrity and security, and to ensure the appropriate use of your Personal Information. These procedures are proportionate to the nature, sensitivity and format of the personal information collected, used, stored or disclosed by us.
Our users the European Economic Area (“EEA”) and European Union (“EU”) should be aware that some companies we work with to provide our Services operate outside the EEA. We only let that happen if we are satisfied with their levels of security. So, keep in mind that when you give us Personal Information it could be transferred, stored or processed in a location outside the EEA or EU.
Transfer of Data
We maintain servers in various locations worldwide and therefore your information may be processed in a jurisdiction different from the one in which you live. We comply with data protection laws in all applicable jurisdictions and provide equal protections to all information.
Retention of Your Information
Any Personal Information given to us will only be held for as long as legally required or permitted and in accordance with the following measures. We will only retain your Personal Information for as long as necessary for us to provide you with our Services or have a legitimate reason to keep it.
YOUR RIGHTS IN RELATION TO YOUR INFORMATION
European Economic Area / European Union Rights
If you reside in the European Union and/or the European Economic Area, you may have certain legal rights relative to the collection and use of your Personal Information. You may have the right to:
- Change and update your information as necessary;
- Have the entirety or part of your Personal Information to be erased or “forgotten”;
- Delete your Personal Information at any time and for any reason;
- Object to, restrict or limit the use of your Personal Information; and
- Ask us for a copy of your Personal Information.
You can do all of this by visiting the "My Account" area on our Site or by contacting our Privacy Team / Data Protection Officer at email@example.com. Where the law provides, you may also send queries to your local data protection authority.
United Kingdom Residents
If you are a resident of the United Kingdom be advised that, after the United Kingdom has left the European Union, we will maintain and treat your data in accordance with the laws of the United Kingdom. We advise that you direct any questions or complaints regarding your rights to the UK Information Commissioner's Office.
Data Protection Officer
If you have any questions pertaining to the collection, use and storage of your Personal Information or any questions relative to this Privacy Notice contact our Privacy Team at firstname.lastname@example.org.
The data controller of your Personal Information is:
Turnswitch Media Limited
27 Broyd Avenue
Feel free to contact us at the above mailing address or at email@example.com if you have any concerns about this Notice or your rights.
Please be aware that if you contact us to assist you, we may need to authenticate your identity before fulfilling your request.