INTRODUCTION

We recognize that persons who access and/or use (“you” or “Users”) our app and other related services, including but not limited to customer supporting, marketing and advertising, (collectively, the “Services”) value their privacy.

This Privacy Policy provides important information regarding:

i) the data collected from you and the ways we collect your data, ii) the reasons why we collect your data, iii) to whom we disclose your data, and iv) the options you have about your personal data.

Unless stated otherwise, this Privacy Policy applies to the Services and all data that we collect from you. We, therefore, provide this Privacy Policy to help you make an informed choice about whether to use or continue using our Services. We may periodically update this Privacy Policy by posting a new version in our app. Your continued use of the Services after the effective date will be subject to the new version of Privacy Policy.

This Privacy Policy is incorporated into, forms part of and is subject to the Terms of Service. Your use of the Services and any personal information you provide on the Site is subject to the terms of this Privacy Policy and the Agreement.

Any terms not defined herein but defined in the Terms of Service shall have the meaning ascribed thereto in the Terms of Service.

I. THE DATA COLLECTED FROM YOU AND THE WAYS WE COLLECT YOUR DATA

1. Data provided by you

To use the Services, you may directly provide certain personally identifiable information to us, such as:

Registered account and password Billing and financial information (Please be reminded that the use of any merchant service provider and/or third-party platforms for the payment of the Admission Fee is subject to the privacy policy of the relevant merchant service providers and/or third party platforms) Other data that you voluntarily provide (e.g. data to identify a lost account)

2. Data collected automatically

When you use the Services, we may use cookies and/or other similar technologies. Cookies are small text files stored by the browser(s) on your desktop computer or mobile device. Most web browsers automatically accept cookies, but you can usually modify browser setting to decline cookies. If you choose to decline cookies, you may not be able to access certain Services and may experience technical problems receiving current information from the cookie-disabled services. The use of cookies and/or other similar technologies is to identify your browsers and to collect data from your device such as:

· Data about your Account · Mobile device identifiers (e.g. your device ID, IMEI) · Data about your device (e.g. device name, operating system, browser type, language, and third-party data statistics like Google Analytic) · Data we collect with cookies, and similar technologies · Data about your use of the Services (e.g. number of clicks)

II. THE REASON WHY WE COLLECT YOUR DATA

1. To provide the Services

To provide the Services, we process data necessary to

· Create Accounts · Allow you to use VPNova’s Services · Operate the Services · Verify and confirm payments · Provide and deliver products and services that you request · Send service-related communications to you

2. To improve and optimize the Services

To provide better Services to you, we have a legitimate interest to collect and process necessary data to

· Update and develop the Services · Manage and update your Account · Develop and improve your experience · Manage the relationship with you · Customize your service experience · Respond to your comments and questions and provide support to you · Provide offers in the Services as well as in other websites and services · Send related information (e.g. updates, security alerts, support messages) to you

3. To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, country, gender, language. We may also use various third-party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to

· Deliver, target and improve our advertising and marketing materials · Pass the information collected from you to third-party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

For information on how to opt-out from receiving personalized advertising and marketing materials, see section 'The options you have about your personal data” below.

4. To secure the Services

Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service safe and fair, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

· Analyze and monitor use of the Services · Moderate and monitor data usage · Prevent cheating, crime or fraud · Take action against fraudulent or misbehaving users · Pass your information to agencies or organizations in charge of crime and fraud prevention and repression

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online.

5. To analyze, research and test

In all of the above cases and purposes, we may use analytic tools, which may include third party’s analytic tools, to carry out research, surveys, and analysis, to create reports for use, to track potential problems of the Services.

6. To obtain your consent

With your consent, we may process personal data for additional purposes.

III. THE OPTIONS YOU HAVE ABOUT YOUR PERSONAL DATA

1. Opt out of advertising and/or marketing materials

You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications.

2. Access and correct the personal data we hold about you You have the right to access and correct your personal data.

3. Other rights

You also have the right to have your personal data deleted, object how we use or share your personal data, and restrict how we use or share your personal data. You can always withdraw your consent.

If you have questions about data protection or any requests for resolving issues with your personal data, we encourage you to primarily contact us through e-mail: freevpnova@gmail.com, so we can reply to you more quickly. We will respond to all requests within a reasonable time frame.

IV. INTERNATIONAL DATA TRANSFERS

By accepting this Privacy Policy, Users understand and agree that your data may be collected, stored, used in any country and/or transferred to any country in the world. Because different countries may have different data protection laws than the Users’ own country, we will try to ensure that adequate safeguards are in place to protect Users’ data.

V. SPECIAL NOTE TO INTERNATIONAL USERS

The use of the App and Services and this Agreement is governed by and shall be construed and enforced under the laws of Singapore, without applying any conflicts of law principles that would require the application of the law of any other jurisdiction. You agree to submit to the personal non-exclusive jurisdiction in Singapore and any other court of competent jurisdiction chosen by us.

In the event of any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, (a “Dispute”), we strongly encourage that a resolution first is sought through our Customer Support service.

You agree that in the event that a resolution is not obtained through our Customer Support service, such Dispute shall be referred by you and may be referred by us to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of three (3) arbitrators, with you appointing one (1) arbitrator and us appointing one (1) arbitrator and the third arbitrator to be selected by the two (2) arbitrators so appointed. The language of the arbitration shall be English.

Notwithstanding any of the foregoing, you agree that we are entitled to submit such Dispute for resolution through any other dispute resolution mechanism including the courts of any jurisdiction and we shall further be entitled to seek any injunctive or other equitable relief in the event of any breach or anticipatory breach by you, without any obligations of providing any bond or surety or proof of damages.

You irrevocably waive all rights to seek any injunctive or other equitable relief or to enjoin or restrain the operation or exploitation of the Services or any part thereof. You further irrevocably waive all rights to a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general action.

VI. OUR POLICIES CONCERNING CHILDREN

The Services are not intended to be accessed by persons under the age of 13, nor do we knowingly collect or solicit personal data therefrom. In the event that we learn that we have inadvertently gathered personally identifiable information from persons under the ages set out below, we will take commercially reasonable measures to ensure that such information is removed from our records.

VII. DATA SECURITY

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you disclose on, through or within the Services and you do so entirely at your own risk. Please note that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice in the app if a security breach occurs.

If you create an Account with the VPNova, you will be required to select a password that can be changed at any time after you first log into the Account by using your current password. You are solely responsible for maintaining the confidentiality of your password and are fully responsible for all activities that occur under your Account and password or your account with any other third party service. Users agree to (i) notify us immediately if you are aware or reasonably suspect of any unauthorized use of your Account or password or of any unauthorized access of the Services through your Account, and (ii) ensure that you exit from your Account at the end of each session.

VIII. MERGER, ACQUISITION, SALE OR INSOLVENCY

1. In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.

2. In the event of our insolvency, reorganization, receivership, winding-up or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

IX. CHANGES AND UPDATES TO THIS PRIVACY POLICY

1. This Privacy Policy may be revised, amended or modified periodically. Please re-visit this page to stay in touch with any changes. Your access of the Services signifies your acceptance and agreement to this Privacy Policy (as may be amended or revised from time to time).

2. For questions about our privacy policy, please submit your questions via email to freevpnova@gmail.com. If you would like to change, modify or update your personal information which you have provided in relation to your Account which you registered with us or pursuant to your access of the Services through your account with any third party service, please submit the request via email to freevpnova@gmail.com.

X. CONTACT US

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting us:

via email to freevpnova@gmail.com.

Last updated October 10, 2018