PRIVACY POLICY

Last modified: 22 DECEMBER 2023

Effective date: 15 MARCH 2021

This Privacy and Data Protection Policy (“Policy”) is effective as of the date set forth above. VAKU APPS LTD (“Company”, “VAKU APPS  LTD”, “We”, “Us”, “Our”), operating with Mobile VPN application (“App”) and website https://vaku.app/ (“Website”), is committed to honoring and encouraging the protection of your privacy as a user who uses the App (“you”, “your”, “User”). You may print a copy of this Policy for your records.

Our Policy is designed to provide an explanation of the information collected by us and our partners, as well as how we use and protect your information when you use our mobile applications, which are available for download on the Google Play Store.

What types of information do we collect?

This page serves as a means to inform visitors about the policies regarding the collection, use, and disclosure of Personal Information when using our app's Services. In this Policy, the term 'personal information' refers to any data that can be used to identify or make an individual identifiable. When you interact with or utilize our Services, we may collect the personal information outlined below. By choosing to use our Services, you agree to the collection and use of information in accordance with this policy. The Personal Information we collect is used to provide and improve the Service. The information that we and/or our partners collect is listed below.

1. We collect the following types of data from you when you use the Services:


We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including providing our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws. Once your Personal Data is no longer needed, we will securely erase or destroy the records in a manner that ensures your continued privacy.


2. Data about your use of the Services 

These data only be passed to the certified third-party statistical platform: Firebase, Google Analytics, Yandex Metrica, etc. 

The above information is only used to improve the product experience. We will not use this information for purposes other than improving the product experience and ad performance. 


3. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated into our app may access certain information, including:

Please note that the information collected by these third-party SDKs is governed by the providers of these SDKs, and we have no control over their practices. These third parties include monetization partners like Google AdMob, Facebook Audience Network, Applovin, Mintegral etc., as well as analytical tools partners like Firebase and Facebook Analytics, Yandex Metrica, etc. Links to the privacy policies of these platforms can be found in the "Cross-border Transfer of Data and Third-party Partner's Privacy Policy" section.


4. Android Advertising ID

We utilize your Android advertising identifier to deliver personalized advertising experiences. This identifier is used solely for advertising and analytics purposes. It does not contain any sensitive user information that can personally identify you or your device. Furthermore, it is not linked to personally-identifiable information or associated with any persistent device identifiers such as SSAID, MAC address, IMEI, and others.


5. Other Information

We may gather information that you provide to us directly and voluntarily. This can include, but is not limited to, your email address, feedback content, and responses to questionnaires.

Remember, We do run automated decision-making software based on all the data we receive. We do use personal information We receive from our Partners, namely the data regarding the time of the User’s actions within the App/Website, the ID of the User’s device, name of version of the app, and the country from which the User has accessed the App/Website for profiling to analyze the Users’ experience within the App, how Users use the Services and App and to enhance the App.

We act as a Joint Data Controller


Joint data controller is a legal person that jointly with other data controllers determines the purposes and means of the processing of personal data, with regard to personal data of Our App Users. We act as a Joint data controller together with the Google LLC (“Google Analytics”, “Google”) and YANDEX LLC (“Yandex.Metrica”, “Yandex”). We determine the purposes of processing of your personal data regarding our business interests. Google and Yandex determine means of processing of personal data and purposes of processing of your personal data regarding their business interests.

This Policy applies to every individual whose personal data is collected by the Google Analytics and Yandex.Metrica (“Partners”) through the App and other persons whose personal data is lawfully disclosed to and processed by our Partners (“Data Subjects”). This Policy describes how our Partners collect and how We and our Partners process the your personal information our Partners collect.

By accepting this Privacy Policy and downloading or continuing to use the Services, you provide your consent for us and our partners to collect and use the information about you that is listed on this page.

Questions, comments and complaints about the data practices related to the App can be submitted to the following address:

VAKU APPS

Email address: help@vaku.app; 

Attention: Christos A. Photiades.

How We Use Personal Data


Our Purposes
Our mobile VPN app is designed to provide a secure and private internet browsing experience on your mobile device. With our app, you can protect your online activities and browse the internet with peace of mind.

Likewise, We will use your personal data for the following purposes:


Processing personal data for marketing purposes
Our Partners process your personal data and allow Us to process your personal data for marketing purposes on the basis of your consent. Our Partners warrant they have received your consent for receiving of marketing communications from us. Marketing communication may include the right of the Company to notify the User about App updates, new services, marketing proposals, and related notifications.

You are not under any obligation to provide our Partners with your personal data for marketing purposes. You can withdraw your consent to your personal data being processed for the purposes of marketing communications at any time by contacting Us at the email address help@vaku.app or directly via the App.

If you do choose to withdraw your consent, this will not mean that Our processing of your personal data before you withdraw your consent was unlawful.


Disclosure of Your Personal Data
We ensure We always include the controls and warranties embodied in this Policy to the contracts and agreements. We work under the respective contracts and agreements with our Partners and contractors whom We grant access to your personal data.

We may further collect and possibly share your Personal Data to enforce the Terms of Service. This may be done to prevent a crime or violation of our Terms of Service or to help solve a transgression that has been committed.

We also reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our App/Website.


Your Age
Before using Our Services, you have to reach the age recommended/established under the Terms of Use and Privacy Policy of Google and Yandex. Google and Yandex ensure and warrant that you have reached the age at which applicable laws permit you to use the App and to collect your personal data. We fully rely on such warranties of Google and Yandex and promptly react to any reports regarding the inappropriate age of Users of the App. We do not normally provide services to subjects of an inappropriate age. Subsequently, We do not process their personal data. We reserve the right to implement any tools and techniques to reveal the human trafficking and exploitation of children and report them immediately to the appropriate state authorities and enforcement agencies, including the personal data associated with the activities which, at Our own discretion, are suspicious and may raise concerns about their association with the violation of applicable laws.

By using or accessing Our App/Website, We believe that such Data Subjects have reached the age recommended/established under the Terms of Use and Privacy Policy of Google and Yandex and have all rights to enter into an agreement with Us as to the receipt of Services and use of App, as well as process personal data under Data Subjects’ consent for the purposes We mention in this Policy.

If you know that our Partners process the personal data of Users of inappropriate age, please inform Us by sending an email to help@vaku.app.


Retention of Personal Data
We do not store your personal data, except the data regarding the time of the User’s actions within the App/Website, the ID of the User’s device, name of version of the app, and the country from which User has accessed the App/Website. Our Partners and We store your personal data collected during your activity on the respective app store or distribution platform and within the App/Website.


We will process your personal data for as long as you will use the App/Website or for as long as needed to provide you with the Services or to legally comply. In case you will stop using the App and delete the App from your device we will not process your personal data anymore, except when it is properly justified under Our business needs.


State authorities, enforcement agencies, and courts
We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency, or a court in case We receive a mandatory request for such disclosure from them.

We may be proactive and address the competent authority in case We suspect a violation of law to be committed in association with your use of Our App/Website.


Your consent
We will notify you of the purposes and scope of the disclosure and ask for your permission in case your personal data is to be shared with a third party not mentioned in this Policy.


Right to Withdrawal of Consent
You have a right to withdraw consent to the processing of your personal data. You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not mean that the processing before the withdrawal is considered thus illegal.

If you want to withdraw your consent to the processing of your personal data, you should contact our Partners, namely Google or Yandex, in this regard, Subject to your withdrawal of consent to the processing of your personal data, our Partners have to inform us about this. Once our Partners will inform Us in this regard, we will stop processing your personal data. We fully rely on our Partners regarding your withdrawal of consent to the processing of your personal data.

Before withdrawing your consent, take into attention the outcome such withdrawal may entail.

What Information Do We Share

As mentioned earlier, we might share your personal information with our trusted third-party partners, which includes providing your personal information to our business partners like advertisers, publishers, and data tracking companies. These partners may use your personal information to show targeted advertisements, analyze your interactions with ads and websites, and gain insights into website and app usage or user behavior in order to improve their services. Please be aware that the use of information by these partners is subject to their individual privacy policies, which are listed below.

To provide you with Antivirus feature the list of installed applications may be shared with our third-party partner, Trustlook Inc. (policy link: https://www.trustlook.com/privacy-policy), to scan installed applications for viruses. Trustlook Inc. provides SDK  for Antivirus feature and only collects information of scanned APK files, including but not limited to package name, signature, code version, hash, file names, size, activities, and services to scan apps for viruses. This SDK does not collect any user information nor the device information such as IMEI, mac device ID, phone number, location, android ID etc. 

Cross-border Transfer of Data and Third-party Partner's Privacy Policy


Our headquarters is in Cyprus. We make every possible effort to protect entrusted data against unauthorized access, including two-factor authentication procedures, regular password changes, due diligence of privacy procedures, and other appropriate and reliable measures provided by Our Partners.


Some data may be accessed and processed by the following companies:


Google LLC (Google Ads, Google Admob, Google Firebase)

Country: Ireland, USA

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://policies.google.com/privacy?hl=en 


Yandex LLC (Yandex Appmetrica)

Country: Russia

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://metrica.yandex.com/about/info/privacy-policy 


Adjust

Country: Germany

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://www.adjust.com/terms/privacy-policy/


Unity Technologies

Country: USA

Purpose: Monetization partner

Policy link: https://unity3d.com/legal/privacy-policy 


Meta

Country: USA

Purpose: Monetization partner

Policy link: https://www.facebook.com/privacy/explanation 


AdinPlay BV

Country: The Netherlands

Purpose: Monetization partner 

Policy link: https://adinplay.com/privacy-and-cookies-policy/ 


AppLovin Inc.

Country: USA

Purpose: Monetization partner

Policy link: https://www.applovin.com/privacy/ 


Pollfish Inc.

Country: USA

Purpose: Monetization partner

Policy link: https://www.pollfish.com/terms/researcher 


Startapp

Country: USA 

Purpose: Monetization partner

Policy link: https://www.start.io/policy/


Inmoby

Country: India

Purpose: Monetization partner

Policy link: https://www.inmobi.com/website-privacy-policy


Ironsourse

Country: Israel

Purpose: Monetization partner

Policy link: https://www.is.com/privacy-policy/


Amazon ads

Country: USA

Purpose: Monetization partner

Policy link: https://advertising.amazon.com/legal/privacy-notice?ref_=a20m_us_fnav_l_prvcy


Chartboost

Country: USA

Purpose: Monetization partner

Policy link: https://answers.chartboost.com/en-us/articles/200780269


Mintegral

Country: Hong Kong

Purpose: Monetization partner

Policy link: https://www.mintegral.com/en/privacy


Verizon

Country: Monetization partner

Purpose: USA

Policy link: https://www.verizon.com/privacy/your-privacy-choices#/


Kidoz

Country: Israel

Purpose: Monetization partner

Policy link: https://kidoz.net/privacy-policies


Monetag

Country: Cyprus 

Purpose: Monetization partner

Policy link: https://monetag.com/privacy/


Adcolony

Country: USA

Purpose: Monetization partner

Policy link: https://www.adcolony.com/privacy-policy/


Csjplatform

Country: Beijing

Purpose: Monetization partner

Policy link: https://www.csjplatform.com/en/privacy


Hyprmx

Country: USA

Purpose: Monetization partner

Policy link: https://jungroup.com/pp/


Smaato

Country: USA

Purpose: Monetization partner

Policy link: https://www.smaato.com/cookie-policy/


Tapjoy

Country: USA

Purpose: Monetization partner

Policy link: https://www.is.com/privacy-policy/


Tencent

Country: Cayman

Purpose: Monetization partner 

Policy link: https://www.tencent.com/en-us/privacy-policy.html


Pangle

Country: Beijing

Purpose: Monetization partner

Policy link: https://www.pangleglobal.com/privacy/partner-en


Liftoff

Country: USA

Purpose: Monetization partner

Policy link: https://liftoff.io/privacy-policy/


Acp-edge.fyber

Country: USA

Purpose: Monetization partner

Policy link: Digital Turbine's Data Protection Addendum


Cleveradssolutions

Country: Cyprus

Purpose: Monetization partner

Policy link: https://cleveradssolutions.com/PrivacyPolicyCAS.html 


Appodeal

Country: USA

Purpose: Monetization partner

Policy link: https://appodeal.com/privacy-policy


Mopub

Country: USA

Purpose: Monetization partner

Policy link: https://www.applovin.com/privacy/


MobFox

Country: Austria

Purpose: Monetization partner

Policy link: https://www.mobfox.com/cookies-policy


Trustlook .Inc

Country: USA

Purpose: To provide Antivirus features this SDK only collects information of scanned APK files, including but not limited to package name, signature, code version, hash, file names, size, activities, and services to scan apps for viruses. This SDK does not collect any user information nor the device information such as IMEI, mac device ID, phone number, location, android ID etc.

Policy link: https://www.trustlook.com/privacy-policy 


We also may use support from the specialists skilled in performing tasks to enhance our Services as well as other independent contractors, e.g. IT specialists, accountants, auditors, lawyers, etc, provided that all adequate safeguards are put in place.

In order to secure the adequate level of protection, We implemented the Standard Contractual Clauses as well as signed Data Processing Agreements in the relationships with the engaged contractors, so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us.


Data Breaches
We take all reasonable steps to minimize the risk of personal data breach while processing personal data. The risk assessment We have to carry out has to determine whether the risk to the rights and freedoms of the Data Subjects affected is judged to be sufficiently high to justify notification to them.

In the case of a personal data breach, We will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the Data Subjects. Also, in the case of a personal data breach, which is likely to result in a high risk to the rights and freedoms of the Data Subjects, We will without undue delay notify the appropriate Data Subject the personal data of which were breached. If measures have subsequently been taken to mitigate the high risk to the Data Subjects, so that it is no longer likely to happen, then communication with the Data Subject is not required.

We will document all personal data breaches, comprising the facts relating to the personal data breach, its effects, and the remedial action taken. That documentation shall enable the competent authority to verify compliance with the GDPR if necessary.


Cookies and Third-Party Technologies

Our Partners use cookies and other identification technologies on the App/Website.


Cookies are small text files that are stores on devices by apps. Cookie may contain your unique identifier and typically serve to improve your experience of Internet surfing: for instance, due to cookies, you are able to browse pages you have once visited quickly, to set your unique options in “settings” menus, as well as monitor your way through the webpages in order to aggregate precise information about your navigation and preferences, so the app owners may analyze the information and offer you a better service and relevant ads in the future.


Purposes to use cookies

Our Partners collect Your cookies for a few reasons:


Third-party websites
Third parties may display their advertisements within the App. When you click on a third-party advertisement, it may redirect you to the website of such a third party outside the App. Such a website may collect your personal data according to its own rules and policies. We are not responsible and hold no liability regarding your personal data by the third-party websites.

We advise you to access the third-party websites carefully and always check their of policies and rules regarding the collection of your personal data.

The Permissions That We Request


Depending on how you engage with our app, we may request specific permissions to ensure its proper functionality. While you have the option to opt out at any time, please be aware that denying these permissions may cause our app to not work as intended. The permissions we may ask for include:

By granting these permissions, you enable us to deliver the full functionality of our app, enhancing your experience. We prioritize the privacy and security of your personal information and adhere to strict data protection practices. Please note that you have the option to revoke or modify these permissions at any time through your device settings.

Your Rights


There is a scope of rights you may enjoy as to personal data protection with regard to GDPR and CCPA.

The list of rights protected under GDPR is as follows:

The list of rights protected under CCPA is as follows:

We pay your attention to the fact that depending on your request regarding the exercising any of your rights provided hereinabove you may need to contact our Partners to exercise such right. 

We do not charge any fees in relation to exercising your rights (unless We receive repetitive requests without a clear justification behind the need to request the information within such short periods of time; in this case, We may charge you a small fee to compensate the expenses that incur due to the repetitive and excessive character of requests). We typically do Our best to answer you as soon as possible or within a reasonable period taking into account the complexity of the request, but in case We are processing a large amount of requests the answer may took Us longer than you might expect.

You can send Us the request via email help@vaku.app or directly via the App. Please verify that your request comprises the details:

We may ask you to provide Us with some information We already have to verify that it is you or the holder of parental responsibility on your behalf.

Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your personal data or disclose your personal data for business purposes.

You might provide us with affirmative authorization to sell your data (the “right to opt-in”). If you are between 13 and 16 years of age, you can provide such services personally. If you are less than 13 years of age, such affirmative authorization has to be provided by your parent or guardian. If you opt in to personal information sales you may opt out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to Us by sending Us a message via email help@vaku.app or directly via the App.

After you make an opt-out request, you may change your mind and opt back into personal information sales at any time by visiting Our App/Website and sending Us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Complaint Lodgement


In case you are convinced We are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority. Our lead authority is:

Name: Office of the Commissioner for Personal Data Protection
Address: Iasonos 1, 1082 Nicosia, Cyprus
Telephone:+357 95 552576
E-mail: help@vaku.app.

We kindly invite you to share your concerns with Us first regarding any issue related to the processing of your personal data. You may use the following channels to address your inquiries:
Email address: help@vaku.app.

Updates to the Policy


In order to improve the quality of Services and to comply with legal requirements, the Company may may update or amend this Privacy Policy at our sole discretion and at any time without providing direct notice to you. It is your responsibility to review this Privacy Policy periodically for any updates or changes. By continuing to use our Service after any such amendments are made, you acknowledge and agree to such amendments and to be bound by the updated Privacy Policy. Please check the following URL for the latest version of our Privacy Policy: https://sites.google.com/view/vaku-vpn-privacy-policy/home.


Continued use of the app after any amendments to the Privacy Policy, and after we have provided you notice of the amended Privacy Policy, constitutes your acceptance of the new Privacy Policy. If you do not agree to the Privacy Policy, you may not access or use the Services and should therefore immediately cease any use of the Services.


Disclaimer of Liability:


a. The use of our website\app  is at your own risk. We shall not be held liable for any direct, indirect, incidental, consequential, or punitive damages arising out of or relating to the use of the app, including but not limited to:

b. We do not warrant or guarantee the reliability, suitability, or performance of the app. The app is provided on an "as is" and "as available" basis, without any warranties, expressed or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, and non-infringement.

c. We make no guarantees regarding the effectiveness, security, or privacy of the VPN services provided by the app. While we strive to protect your data and ensure a secure browsing experience, you acknowledge that no method of transmission over the internet or electronic storage is completely secure.

d. We do not assume any responsibility for the actions, content, or policies of third-party websites or services that may be accessed through the website\app. Any interaction or transaction with third parties is solely between you and the third party, and we shall not be liable for any loss or damage arising from such interactions.

e. The information provided through the app is for general informational purposes only and should not be considered legal, financial, or professional advice. We do not guarantee the accuracy, completeness, or timeliness of the information and recommend consulting with qualified professionals for specific advice.

f. Our liability, if any, shall be limited to the maximum extent permitted by applicable law.

g. You agree to indemnify, defend, and hold us harmless from any claims, damages, losses, liabilities, and expenses (including legal fees) arising out of or related to your use or misuse of the app, violation of any laws or regulations, or infringement of any third-party rights.

h. This disclaimer shall be governed by and construed in accordance with the laws of Cyprus. Any legal actions or proceedings arising out of or relating to this disclaimer shall be exclusively held in the courts of Cyprus.