We believe everyone has the right to digital privacy. Along with digital privacy, consumers also have the right to transparency. Because you are entrusting us with your data, we believe it is even more important that we are transparent with you regarding what information we collect, how it is collected, from where it is collected, and why it is necessary to collect. We wrote this privacy policy with you in mind, attempting our best to provide a comprehensive yet easy to understand document.
LatinVPN does not collect, monitor, or log your browsing activity, such as what websites you went on, when connected to the VPN Service.
We collect aggregated and anonymous performance data to improve functionality and product performance, diagnose crashes, identify bugs, and optimize server performance. This aggregated and anonymous data does not include IP address, connection time stamps, or DNS inquiries.
Our goal is to collect and retain the least amount of data. However, we have to collect and retain some data, such as email address and billing information, which allows for you to continue using the VPN service.
We do not sell or rent your personal information to third parties.
You have the right to request, review, and request deletion of your personal data.
If you have any questions regarding this privacy policy or the information that is collected you may reach out to our support team or make a privacy request via soporte@LatinVPN.com.
This Policy explains how we collect and store (“Process”) Personal Data. The Policy applies to the information we collect about visitors (the “you”) to www.LatinVPN.com (the “Site“) and subscribers (the “you”) to the LatinVPN VPN service (the “Services” and “App”), which are owned and operated by LatinVPN (“Company”, “we”, “us” and “our”). For the purposes of this Policy, Company is the Controller. Terms used in this Policy are explained in Section I below.
From time to time, we may change or update this Policy, without prior notice to you. Your continued use of the Site or Services constitutes your acceptance of the then-effective Policy.
Our Terms of Service, including their limitation on liability, apply to this Policy. You can read them here.
If you have any questions regarding this Policy, the information that is collected, or GDPR request, contact details are provided in Section N below.
We collect Personal Data: directly from you, through the use of the Site, and through the use of the Apps.
How we obtain personal data:
You: This data is collected when you fill out a form on our website; subscribe to the VPN Service; when you contact us via email, chat, telephone, social media platforms, or by any other means; when you publicly submit reviews on forums, review platforms, or any other means.
Our Sites: This data is collected when you visit any of our Sites, our partner and affiliate sites, or interact with our advertisements.
Our App: This data is collected when you download, install, or use our Apps.
Why we obtain personal data:
Provisioning of Services. To create your account, collect payment for our Services, verify your identity when you log into the Site, and administer accounts.
Operating and Improving the Site. To better understand how our Site is found, how visitors engage with our Site, provide visitors with relevant content or advertisements, identify issues with our Site, plan improvements to our Site or to create new Sites.
Operating and Improving the App. To identify Service performance issues, improve App performance, fix bugs, plan improvements to our App or to create new Apps.
Communications. To send you information about industry news, product updates, changes to any of our Sites or Apps, to send you offers made available by us, our affiliates, or our marketing partners and to respond to your requests for help and technical assistance.
We may also create Personal Data about you, such as records of your interactions with our customer service department or details of your payments to us.
You are not required to provide any personal data to browse our Site. If you wish to subscribe to our Services, you will need to provide an active email address and billing information.
We may Process the following categories of Personal Data about you:
The Site: We process aggregated anonymous personal data from Site visitors using cookies, pixels, and similar technologies, such as Google Analytics. Depending on your browser privacy settings the aggregated anonymous data may include: browser type, device type, operating system, average time spent on our site, pages visited on the site, interactions with our content or advertising, gender, age, language preference, and country. The focus of this data collection is to improve our Site performance and provide you with the best browsing experience.
The Service: In order to subscribe to our Services you must first create an account. This will result in us creating a purchase history for the purpose of maintaining an active subscription to the Service. Depending on your purchase origin (website, Google Play Store, Apple App Store) and chosen payment method (credit card, PayPal, etc) the data collected may include: email address, name, billing address, credit card information, IP address, and affiliate tracking data. We will only use this information to process payments, and detect and prevent fraudulent transactions. We do keep a historical record of credit card charges for accounting purposes. Once you have created an account, this personal information can be modified by you at any time through your Account Control Panel.
The App: We process aggregated anonymous data to improve the quality of our Apps and Services. The data collected may include: User’s language preference, device brand, device model, OS version, country, crash reports, session lengths, server usage, protocol, build version, UI interactions, API requests and response codes, and app build version. Our VPN applications utilize analytic tools to gather and report performance data anonymously. We respect the privacy of our customers and only use this aggregated anonymous data to diagnose crashes, identify bugs, optimize server performance, and provide you with the best App experience.
The client apps themselves do maintain connection logs which are stored as diagnostic files on your device. Diagnostic connection files are made available solely for the purpose to assist with troubleshooting. The macOS and iOS app diagnostic logs are disabled by default, so if you require assistance where diagnostic logs are necessary, the support team may ask you to enable the setting. We do NOT have access to the connection logs unless provided by you, the user, to our support team through a diagnostic file. If for any reason you need to submit a diagnostic file to our support team you may modify the file and remove any personal data and/or request for the file to be redacted from the support interaction.
As a service provider we send transactional and promotional emails. Transactional emails are necessary to ensure continuation of services and include account activation, billing, password, and support related communications. You may also receive promotional emails about privacy & security industry news, service updates, product updates, feature releases, and other information we think may interest you. Transactional emails include the following:
Account activation – After a successful completion of purchase you will receive an email address verification email which is necessary to activate your VPN Service subscription. Upon confirming your email you will receive an additional email with your subscription details.
Payment warning and failure – These emails inform you when there is a problem with your payment method and advise on how to prevent service interruption.
Account cancellation – This email confirms your cancellation request and explains how to reactivate your account, if you wish to.
Account termination – This email confirms that your LatinVPN account has completed termination and explains how to reactivate your account, if you wish to.
Password reset – This email provides a unique password-reset link and instructs how to complete your password reset.
New password – This email confirms your password reset and explains how to change your password in the future, if you wish to.
Customer Support – If, for any reason, you reach out to customer support, we may use emails to communicate with you, follow up from a call-in support inquiry and send chat transcripts. This will result in us creating a support history for the purpose of improving our Services.
Promotional emails include the following:
Product – All new subscribers to LatinVPN receive product awareness emails. These emails offer application tips and helpful hints to LatinVPN account holders who may be unfamiliar with the benefits and inner-workings of a VPN.
Other – Additional promotional emails you may receive from us include industry related news, special offers, surveys, feedback requests, new feature releases, and service updates.
Unsubscribing From Promotional Emails
You may unsubscribe from our promotional email list at any time by following the unsubscribe instructions included in every promotional email we send. We will not send you promotional emails from a list you have unsubscribed from, but we may continue to contact you, if necessary, for the purposes of continuation of the Service or from additional lists you have signed up under.
We respect your privacy and do not seek to collect or otherwise Process your Sensitive Personal Data. If we ever need to Process your Sensitive Personal Data for a legitimate purpose, we would do so in accordance with applicable law.
We may Process your Personal Data for the following purposes:
Provision of services: providing our Sites, Apps and services to you, as well as operating, managing and improving our Sites and our Apps, providing content through them to you, maintaining and improving them, and notifying you of changes to them.
Communications: communicating with you by any means you have provided to us
Administrative matters: processing to support sales, finance, corporate audits, vendor management, legal compliance, and preventing and investigating breaches of policy or law.
Security: helping secure your Personal Data,
Legal proceedings: establishing, exercising or defending legal rights.
We may rely on the following legal bases for Processing your Personal Data:
Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
Contractual necessity: We Process your Personal Data where the Processing is necessary in connection with providing contracted-for VPN services to you;
Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law.
We use third-party services to assist us with processing payments, fraud detection, improving website performance, app crash information, and email communications. These service providers receive only the information needed to perform their designated functions, and are not permitted to use the information for their own marketing, advertising or research purposes. We do not sell personal information to third parties. We closely review any third party requests we receive for customer information. Since we do not collect, monitor or log your browsing activity, we do not have logs of your browsing activity to provide in response to third party requests. We cannot provide information that we do not have, and we otherwise provide information only when we are legally required to.
“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
“Sensitive Personal Data” includes data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
“Site” means any website operated, or maintained, by us or on our behalf.
We implement appropriate technical and organizational security measures to protect your Personal Data.
In the workplace: We use appropriate security measures to protect your personal information from loss, theft, misuse, or unauthorized access. All of our employees are kept up-to-date on these best practices. In addition, we restrict employee access to service administrative panels to only those who require such access in order to perform their job functions.
On the internet: We seek to safeguard your data. Where appropriate, we use encryption, access controls, passwords, and physical security measures to protect the information we collect and maintain about you against unauthorized access and disclosure. However, because the internet is an open system, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted using the internet.
We take every reasonable step to limit the volume and minimize the retention period of the Personal Data that we Process.
We take every reasonable step to ensure that your Personal Data is kept accurate, up-to-date, and erased or rectified if we become aware of inaccuracies.
Your Rights With Respect to Your Personal Information:
Right to Withdraw Consent: Where you are requested to consent to the processing of your personal information, you have the right to withdraw your consent at any time.
Right to Know: You have a right to know what personal information we collect, process, and share or sell. This policy is meant to provide transparency with regard to your data. If you have additional questions, you can email us at soporte@latinvpn.com
Right of Access: You can request a copy of the personal information we have collected about you from us.
Right to Delete/Erase: You can request us to delete all the information we have collected about you. It is important to note that by exercising your right to deletion you may lose access to your account and any purchases, points or features associated with it. If you wish to cancel your account or request that we no longer use some or all of your information to provide you services, contact us at soporte@LatinVPN.com.
Right to Request Rectification: If you find that any of your information that we are processing is inaccurate, you can contact us to have your information corrected. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For certain requests, we may require additional information.
Right to Opt-out of the Sale or Sharing for Targeted Ads: You have the right to refuse to have your data sold or shared. We confirm we have not sold or shared consumer data in the last 12 months, nor do we currently. If you have additional questions you can contact us at soporte@LatinVPN.com.
Right to Object to the Processing: You can object to our processing of your personal information via our privacy portal, under certain circumstances. By objecting to processing, you may not be able to access some or all of our services. This right is limited to personal data processed for commercial purposes.
Right to Object to the Use of Sensitive Personal Information: You have the right to object to our use of your sensitive personal information. Sensitive personal information is information about your health, race, religion, sexual orientation, gender identity, political opinions or philosophical beliefs. You should always be mindful about the personal information you share online, especially when it is sensitive in nature.
Right to Object to Automated Processing: You have a right to object to the processing of your data for the purposes of automated decision making about you.
Right to not be Discriminated Against: You have a right to not be discriminated against for exercising your rights.
Right to Withdraw Consent: Where you are requested to consent to the processing of your personal information, you have the right to withdraw your consent at any time.
You may be required to verify your identity before we can give effect to these rights. If you are making a request on behalf of a user, we require a signed authorization letter from the consumer.
Please contact us at soporte@LatinVPN.com to submit a Data Subject Access Request; to submit a Data Subject Erasure Request; to exercise other rights regarding your data; to provide any comments, questions or concerns about any of the information in this Policy; or to raise any other issues regarding the Processing of Personal Data carried out by us. Your request will be routed to our privacy team.
You may also contact us as follows:
LatinVPN
11421 NW 39TH ST
Doral, FL 33178
Attn: Legal Department
soporte@LatinVPN.com
