1. Introduction
This Privacy Policy explains how CVPN (“we”, “us”, “our service”) collects, uses, shares, and protects personal data when you use CVPN websites, applications, and services (the “Services”). By using CVPN, you agree to data processing in accordance with this Policy.
We aim to protect your privacy and process data in accordance with applicable laws, including the GDPR where applicable.
2. Data we collect
Account data
- for example: Telegram ID (to provide access and communicate), username (if available)
Payment data (for paid subscriptions)
- amount, currency, date, part of a payment identifier (for example, the last 4 digits), payer email (if provided)
- payments are processed by trusted partners; we aim not to store raw card data
Communication data
- support messages and technical information when needed to resolve an issue
Technical data
- service health data (diagnostics/crashes) and minimal web logs used for protection and stability
3. How we use data
To create and manage accounts, provide and improve the Services, process payments, prevent fraud, support users, perform analytics, and send important notifications.
4. Data sharing
We do not sell or exchange personal data. We may share data only with:
- trusted providers (payments, email, analytics, support) — strictly as necessary
- competent authorities — only where required by law and pursuant to a legally valid request
- affiliated companies (if any) — where necessary to operate the service
- a buyer/successor — in connection with a merger or sale of the business
5. VPN server locations
Some server locations may be in different countries. We inform users when they select locations. We do not cooperate with government authorities in countries where doing so would conflict with the law and/or data-protection principles, and we do not transfer user data to them without a lawful basis.
6. Retention periods
- billing/financial records: up to 10 years (where required by law)
- marketing consent records: up to 3 years or until consent is withdrawn
- support request data: up to 3 years
- technical diagnostics: up to 6 months
7. Your rights
You may request access, correction, deletion, or export of your data; restrict or object to processing; withdraw consent; and file a complaint with a supervisory authority. We aim to respond within 30 days.
8. Security
We use encryption, firewall policies, access controls, and organizational security measures. In the event of a confirmed breach, we will notify users and/or regulators where required by law.
9. International processing
Data may be processed in different countries. Where necessary, Standard Contractual Clauses (SCCs) and other data-protection mechanisms are used.
10. Business transfers
If the business is reorganized, merged, or its assets are sold, data may be transferred to a successor, while remaining protected under this Policy.
11. Children
CVPN is not intended for persons under 18. If we discover such data, we will delete it within a reasonable period.
12. Policy updates
We may update this Policy. Material changes may be announced on the website or through notifications before they take effect.
13. Contact
Phone: +7 994 013-40-42
Email: insight.inc@ro.ru
Telegram: @insightdev0