Privacy Notice

Effective date: Feb 2th 2023

We recognise that privacy is important. This Privacy Notice ("Notice") describes how OneTap VPN Studio("we", "our" or "us") collects, processes, and protects personal data about you through the OneTap VPN app (the "App" or "Services"). This Notice also describes your rights in relation to your personal data.

If you have any questions about this Notice or how we use your data, our details are provided in the "Contact Us" section below.

This Notice may be provided in more than one language. In the event of any conflict, where permitted under local law, this English language version of the Notice shall prevail.

1. PERSONAL DATA THAT WE COLLECT

Personal data is information, or a combination of pieces of information that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly (e.g., when you contact us), information we generate about you in the course of our relationship with you, and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law), and third-party services (such as third-party social media companies, advertising partners, and analytics providers). 

We may also collect certain personal data about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time when your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

We may automatically collect the following categories of personal data from and about you when you use our interact with our App:

1. Device information (e.g., MAC address, device ID, GAID);

2. Network information (e.g., IP address);

2. HOW WE USE YOUR PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We may use your personal data for the following purposes:

1. create user ID and support users to use this App;

2. service improvements: provide operation and maintenance support;  

3. serving advertising: we serve you advertisements (non-personalized advertisements) and measure the effectiveness of the advertisements; 

We must have a legal basis to process your personal data, as specified under applicable laws. In most cases the legal basis will be one of the following:

1. as consented by you in respect of this Notice;

2. to fulfil our contractual obligations to you, for example to provide the services you request;

3. to comply with our legal obligations, for example to obtain proof of your identity to enable us to meet our fraud prevention and anti-money laundering obligations;

4. where permitted under applicable laws, to meet our legitimate interests, for example:

   1. to understand how you use our services and to enable us to derive knowledge that enables us to develop new services;

   2. to carry out data analysis to ensure the stability and security of our Services and prevent crime, fraud and misuse of our Services;

   3. to provide non-personalised advertising, which keeps most of our services free; and

   4. to improve user experience.

When we process personal data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected;

1. we may obtain your separate consent to collect and use certain types of personal data when we are required to do so by law (for example, in relation to our direct marketing activities). If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this Notice; and

2. as otherwise may be permitted under applicable laws.

3. HOW AND WHEN WE SHARE YOUR PERSONAL DATA

We may share your personal data as follows:

1. With advertisers and third-party measurement companies to show how many users of the App have clicked on that advertisement.

2. With potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal data to use it in a manner consistent with this Notice.

4. INTERNATIONAL DATA PROCESSING & TRANSFER

We will store your personal information in Singapore.

Where permitted under applicable laws, your personal data may be transferred to and processed outside of your jurisdiction, including, if you are an EU or UK-based user of the Services, in a country that is not regarded as ensuring an adequate level of protection for personal data under European Union law / by the European Commission or under UK law / by the UK Government.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information below.

5. DATA SECURITY AND RETENTION

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

We retain your personal data for as long as we have a relationship with you. After our relationship has ended, we retain your information as long as required by law. We may also retain records to investigate or defend against potential legal claims, deal with any complaints or official enquiries or investigations regarding the Services, or maintain business records for analysis and/or audit purposes.

6. YOUR RIGHTS OVER YOUR PERSONAL DATA

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

1. access – request a copy of your data and information relating to how it is processed;

2. rectify – request any inaccuracies in the data we hold about you be corrected;

3. erase – request that we erase your data from our records;

4. restrict – request that your data is no longer processed by us to the full extent set out in this Notice;

5. object – object to certain ways that we process your data;

6. transfer – request that your data be shared with a third party;

7. withdraw your consent – where we are relying on your consent to process your data, then you can withdraw your consent at any time; and

We also encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. Please note that we may require additional information from you in order to honour your requests. 

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below.

7. CHILDREN'S INFORMATION

The Services are not directed to children, and we do not knowingly collect any personal data from children under the age of 13 (or such legally required age of consent as defined under applicable laws) or knowingly allow such person to register on our Services. In the event that we are notified that we have collect personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible. If you believe that we might have any information from a child of or under 13 (or such legally required age of consent as defined under applicable laws), please contact us at the contact details provided below.

8. CONTACT US

We are the controller responsible for the personal data that our services collect and processes. If you have questions or concerns regarding the way in which your personal data has been used or would like to exercise any right, please contact us at:support@uniqueads.top.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

9. CHANGES TO THE NOTICE

You may request a copy of this Notice from us using the contact details set out above. We may modify or update this Notice from time to time.

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) or to terminate your use of the Services.