Cool VPN Privacy Policy

As set forth in the Privacy Policy on the Software (Cool VPN) (hereinafter referred to as “Privacy Policy”), except as otherwise specified herein, we will not intentionally disclose any information involving your personal privacy to any third party without your prior approval.

1. Information we collect as you use the VPN service provided by Cool VPN

(1) device attributes, including but not limited to IP addresses, network card (MAC) addresses, open unique device identifiers and advertisement identifiers or other permanent or non-permanent device identifiers ("device identifiers");

(2) device software platform and firmware;

(3) mobile phone operators;

(4) Geographical data such as zip code, area code, and rough positioning;

(5) Other non-personal information that we reasonably need to improve our services and other services and products.

2. How Cool VPN will use your personal information

(1) Determine whether you can use the VPN service we provide now by your IP address, network card (MAC) address, geographic location, and network service status.

(2) Implement password recovery function through your personal information;

(3) Sending the service information of the mobile mobile app to you through your personal information;

3. Personal information security

Keeping your personal data safe is critical to us. We will use it carefully and do some data encryption. In both the data transfer and data retention phases, we protect the information you submit to us through widely accepted industry standards such as firewall, encryption, and data privacy legal requirements. However, no Internet transmission or electronic storage method is 100% secure. Therefore, although we protect your personal information in a commercially acceptable manner, there is no guarantee that the information will be absolutely secure.

4. How long will the software keep personal information?

In general, the Software retains only your personal information for the period of time required for the purpose of collection and will comply with the data retention period as required by applicable law.

5. WHY Cool VPN COLLECTS DATA

We use the information we collect from all our services for the following purposes:

Provide our services

We use your information to deliver our services

Provide personalized services

We use the information we collect to customize our services for you, including providing recommendations, personalized content.

Communicate with you

We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity, like an attempt to sign in to your Cool VPN Account from an unusual location. Or we may let you know about upcoming changes or improvements to our services. And if you contact Cool VPN, we’ll keep a record of your request in order to help solve any issues you might be facing.

Protect Cool VPN, our users, and the public

We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Cool VPN, our users, or the public.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

6. YOUR PRIVACY CONTROLS

(1) Managing, reviewing, and updating your information.

Your personal information

You can view and update your personal information in My Account.

Your personalized information

You can review and update your personalized information in My Account.

(2) Deleting your information

When you delete an Cool VPN account, your personal information and the contents under your account will be deleted.

In some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes. You can read about Cool VPN’s data retention periods, including how long it takes us to delete your information. We try to ensure that our services protect information from accidental or malicious deletion.

7. We build security into our services to protect your information

Cool VPN account is built with strong security features that continuously protect your information. The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected.

We work hard to protect you and Cool VPN from unauthorized access, alteration, disclosure, or destruction of information we hold, including:

(1)We use encryption to keep your data private while in transit

(2)We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems

(3)We restrict access to personal information to Cool VPN employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

8.How We Process the Minor’s Data

This Product is not intended for a minor under 3 years old (or equivalent minimum age set by the laws of EU members). We will only process the information of these minors to the extent permitted by law and with the consent of their guardians. We will implement relevant technical measures and make our best efforts to verify whether the processing of minors’ information has been approved by their guardians. We will try to delete relevant data as soon as possible if we are aware that we have collected the personal data of a minor without the prior consent of their certified guardians.

9. How Your Personal Data Is Transferred Globally

We provide Cool VPN products and services around the world, which means to conduct business globally, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region where you use this Product.

Personal data protection legislation in such jurisdiction might be different or even absent. Under such circumstance, we will adopt various measures to ensure security of your personal data. For instance, we will ask you for your explicit consent before transmission of your personal data, or implement security measures such as encryption and pseudonymisation during data transmission; when your personal data is transferred to such jurisdictions, we will apply the same protection of your personal data in accordance with the Policy. We will endeavor to protect your personal data with the measures stipulated in Article 46 and Article 47 of the EU General Data Protection Regulation.

10. Update of Privacy Policy

We reserve the right to revise or modify this Policy. For any update of this Policy, we will send you notice on the interface of this Product to remind you of relevant updates and indicate the updated provisions for your ease of reading. Please do completely read and fully understand the updated Privacy Policy. By continuing to use this Product, you will be deemed to have accepted the updated version of this Policy. We will not reduce your rights under this Policy without your explicit consent.

11.Privacy Issues

If you have any questions or concerns about the software's privacy policy or data processing, please contact the customer service within the APP.