Privacy Policy

This Privacy Policy applies to:

• our mobile applications;
• our website and related web pages;
• communications with support;
• activity related to subscriptions, payment and account management within the Service.

This Privacy Policy does not apply to third-party services that have their own privacy policies, including app stores, payment operators, advertising providers, analytics providers and third-party sites linked from the Service.

We collect only the information that is reasonably necessary to operate, protect, support and improve the Service, comply with legal requirements, and manage subscriptions and advertising.

2.1 Information you provide directly. We may collect information you provide to us, for example: your email address if you contact us or create an account; support requests, feedback, bug reports or other communications; any information you choose to include in support messages or feedback forms.

2.2 Subscription and transaction information. If you purchase a premium plan or other paid feature, we may receive limited transaction-related information, such as: subscription status; product identifier / plan type; transaction or purchase token / receipt identifier; purchase, renewal, expiry, cancellation, refund or billing status; country, currency or storefront, where such information is provided by the platform. We do not collect or store your full bank card number or full financial account details when payments are processed by app stores or authorized payment providers.

2.3 Advertising-related information. If you use the free version of the Service or otherwise view advertising, our advertising partners may collect or receive information such as: device identifiers, including advertising identifiers, where available; IP address; data about interaction with the app and advertising; information about the device, network and app; crash, diagnostic and performance data; approximate location derived from IP address or device settings, where permitted. Such information may be used to display advertising, measure its effectiveness, prevent fraud and, where permitted by law and your settings, personalize advertising.

2.4 Device, app and diagnostic information. We may collect limited technical information necessary to provide and maintain the Service, including: app version; operating system version; device model; language and region settings; crash logs and diagnostic data; performance metrics; installation identifiers or internal app instance identifiers; information needed to fix errors and maintain service stability.

2.5 VPN operational data. To operate the VPN, we may process a limited amount of technical or operational data, for example: the selected server or server region; connection attempt status (e.g., success/failure); connection timestamps or session events in a limited form, where necessary for operation, abuse prevention, troubleshooting, applying service limits or subscription control; aggregated traffic consumption or usage counters; signals for countering abuse, fraud and violations of the integrity of the Service. We design our systems to minimize the amount of VPN-related information collected and retained.

We do not log, track or store:

• your browsing history;
• the content of your communications;
• DNS queries related to your online activity, except where strictly necessary for the technical operation of the Service and not retained as an activity log;
• destination addresses or websites you visit through the VPN tunnel;
• the content of data transmitted through the VPN connection.

If temporary technical processing is nonetheless required to establish or maintain a connection, it is limited only to what is necessary to deliver the Service in real time and is not used to build profiles of online behavior.

We may use information for the following purposes:

• providing, operating, protecting and maintaining the Service;
• authenticating purchases, verifying subscriptions, restoring access rights and managing premium features;
• displaying advertising in the free version of the Service;
• measuring advertising effectiveness and preventing invalid traffic, fraud, abuse and misuse;
• troubleshooting, debugging and improving app performance and reliability;
• responding to support requests and communicating with users;
• monitoring service capacity, availability and infrastructure health;
• enforcing our Terms of Use and other policies;
• complying with legal obligations and lawful requests from government authorities;
• protecting our rights, users, systems and operational activity.

Where applicable under the GDPR, UK GDPR or similar laws, we process personal data on one or more of the following legal bases:

• performance of a contract: to provide the Service you requested;
• legitimate interests: to protect, maintain, improve, support and monetize the Service, including ad-supported access and fraud prevention;
• consent: where required, including for certain advertising mechanics, tracking or privacy choices;
• legal obligation: where processing is necessary to comply with applicable law.

The Service may include advertising, including via Google AdMob and related advertising partners, especially in the free version of the Service.

Where required by applicable law, we will request consent before using personal data for personalized advertising or before enabling tracking technologies that require consent. You may also have the right at any time to withdraw or update your advertising privacy settings through device parameters, in-app privacy settings or applicable consent tools.

Even if you opt out of personalized advertising, you may still see non-personalized advertising.

Premium access may be provided through auto-renewing or recurring subscriptions, one-time purchases or other permitted billing methods.

If you make a purchase through the Apple App Store, Google Play or another marketplace:

• the relevant store or payment provider processes the transaction;
• we may receive only limited purchase metadata necessary to verify and manage your access entitlement;
• billing, renewal, cancellation, refund and payment-method management may be governed by the relevant store or provider in accordance with their own terms and privacy policies.

If local law or platform rules require additional payment disclosures, such disclosures will be provided on the app listing, the checkout flow or the in-app purchase screen.

We do not sell your personal data for monetary consideration. We may share limited information in the following cases:

8.1 Service providers and processors. We may share information with providers who help us operate the Service, for example: cloud hosting and infrastructure providers; user support tools; crash reporting and diagnostics providers; analytics or performance monitoring providers; advertising and monetization partners; payment or subscription verification providers. Such providers are authorized to process information only to the extent necessary to provide services to us, subject to contractual, technical or legal safeguards.

8.2 App stores and payment platforms. Where premium features are sold through app stores or marketplaces, these platforms may process personal and transaction data in accordance with their own privacy policies.

8.3 Legal compliance and protection. We may disclose information if we believe in good faith that disclosure is necessary to: comply with a law, regulation, court order or lawful request; investigate fraud, abuse or security incidents; protect the rights, property and safety of our users, business and systems.

8.4 Corporate transactions. If we are involved in a merger, acquisition, financing, restructuring, asset sale or similar transaction, information may be disclosed as part of that process, subject to appropriate confidentiality and legal safeguards.

Your information may be processed in countries other than your country of residence. Such countries may have different data protection laws.

Where required by law, we apply appropriate safeguards for cross-border transfers, such as contractual protective measures, provider obligations, internal access controls and other legally recognized transfer mechanisms.

We retain personal data only for as long as is reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide the Service;
• maintain subscriptions and purchase-related rights;
• comply with tax, accounting, legal and regulatory obligations;
• detect and prevent fraud and abuse;
• resolve disputes and enforce agreements.

Retention periods may vary depending on the type of data, how the Service is used and legal requirements. When data is no longer needed, we delete, anonymize or securely isolate it where immediate deletion is not possible.

We apply reasonable technical, organizational and administrative safeguards designed to protect personal data against unauthorized access, disclosure, alteration or destruction. Such measures may include:

• encryption in transit;
• access control and the principle of least privilege;
• secure infrastructure and monitoring;
• logging and incident response measures related to platform security;
• vendor review where appropriate.

No method of transmission, storage or security measure is completely error-free, and we cannot guarantee absolute security.

Depending on your location, you may have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain data, where applicable;
• lodge a complaint with a competent data protection authority.

You may also have choices regarding:

• ad personalization and tracking;
• device advertising identifiers;
• push notifications;
• subscription cancellation and renewal settings through the relevant app store;
• account deletion, where an account feature is offered.

To exercise applicable rights, contact us at novavpnplatform@gmail.com. Before fulfilling some requests, we may need to verify your identity.

If you are a resident of California or another U.S. state with applicable privacy legislation, you may have additional rights regarding access, deletion, correction, portability and opting out of certain processing.

We do not sell personal information for monetary consideration. If applicable law treats certain advertising-related disclosures as a “share” or targeted advertising, you may have the right to opt out of such processing through available privacy settings, consent tools or by contacting us.

The Service is not intended for children under the minimum age established by applicable law and, under no circumstances, for children under 13.

We do not knowingly collect personal data from children in violation of applicable law. If you believe a child has provided us with personal data, contact us, and we will take the necessary steps to investigate and, if required, delete such information.

Our Service may integrate with or contain links to third-party services, including:

• Google AdMob and related advertising technology providers;
• the Apple App Store, Google Play and related billing/subscription systems;
• analytics, diagnostics and infrastructure providers.

Such third parties may process data in accordance with their own privacy policies. We recommend that you review them separately.

We may update this Privacy Policy from time to time to reflect changes in the Service, technology, legal requirements or business practices.

When we make material changes, we will update the “Last updated” date and, where required, provide additional notice in the app, on our website or by other appropriate means.

If you have questions, requests or complaints regarding this Privacy Policy or our data processing practices, please contact us:

• novavpnplatform@gmail.com