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CHILD SAFE VPN LTD PRIVACY POLICY

Last Updated: 1st September 2019

BACKGROUND:

Child Safe VPN Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://childsafevpn.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when agreeing to our Cookie Policy and registering and/or subscribing to Our services.

 

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

 

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site; Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003, EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018;

 

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the Data Protection Act EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018;

“We/Us/Our”

means Child Safe VPN Ltd, a limited company registered in England under company number 12111771, whose registered address is Unit 9 The iO Centre, Skeffington Street, The Royal Arsenal, Woolwich, London SE18 6SR.

 

  1. Information About Us
    • Our Site is owned and operated by Child Safe VPN Ltd, a limited company registered in England under company number 12111771, whose registered address is Unit 9 The iO Centre, Skeffington Street, The Royal Arsenal, Woolwich, London SE18 6SR.
    • Our Data Protection Officer is Stuart Brown, and can be contacted by email at dpo@childsafevpn.com, by telephone on 02081918528, or by post at Child Safe VPN Ltd, Unit 9 The iO Centre, Skeffington Street, The Royal Arsenal, Woolwich, London SE18 6SR.
    • Our Employees are all Enhanced DBS Checked.
    • We have completed both the UK Government Cyber Essentials Certification, IASME Gold Certification including GDPR as well as the UK Police Digital Security Centre Digitally Aware program
    • Our ICO Reference # A8481916
  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  • The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  • The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

  1. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy /cookie-policy. We do not collect any ‘special category’ or ‘sensitive’ personal data or any personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected

How we Collect the Data

Identity Information including name and title.

On subscribing to our Child Safe VPN Service.

Contact information including email address, physical address and mobile telephone number.

On subscribing to our Child Safe VPN Service.

Payment information collected by our third-party payment provider. No payment details are stored on Our servers.

On subscribing and/or renewing to our Child Safe VPN Service.

Profile information including a non-personal id and encrypted password to access Our VPN service as well as subscription details.

On subscribing to our Child Safe VPN Service.

Technical information is not stored unless required for a short period to troubleshoot any service issues – deleted immediately. Minimal information to solve issues at hand.

On using the Child Safe VPN Service.

Data from third parties including website analytic and payment information.

On subscribing and/or renewing to our Child Safe VPN Service.

 

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and Our lawful bases for doing so:

What we Do

What Data we Use

Our Lawful Basis

Registering you on Our Site.

Email address, User-selected Password

Title, First Name, Last Name and Billing Address incl Country and Postcode.

Optionally subscribe to our newsletter.

Contractually necessary to provide the service(s) signed up for and purchased

Sending Child Safe VPN secure password

Mobile Phone Number (via WhatsApp)

Contractually necessary

Providing and managing your Account.

Email Address & Password.

Contractually necessary to provide the service(s) signed up for and purchased

Providing and managing your access to Our Site.

Email Address & Password.

Contractually necessary to provide the service(s) signed up for and purchased

Personalising and tailoring your experience on Our Site.

Cookie

User consent via Cookie and Privacy Policies

Administering Our Site.

Orders, Payments, Refunds, Cancellations.

Contractually necessary to provide the service(s) signed up for and purchased

Administering Our business.

Accounting Data.

Lawful processing – legal obligations

Supplying Our services to you.

VPN System ID and VPN System Password.

Contractually necessary to provide the service(s) signed up for and purchased

Managing payments for Our services.

Accounting Data.

Lawful processing – legal obligations

Communicating with you.

Email Address, Mobile Phone Number.

Contractually necessary to provide the service(s) signed up for and purchased

Supplying you with information by emailthat you have opted-in-to (you may opt-out at any time by administering preferences in My Account or Unsubscribe link in Email.

Email Address

User consent

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on Our products or services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data

How Long we Keep It

Identity Information

For the duration of the subscription to Our service plus any length of any relevant legal obligations.

Contact information

For the duration of the subscription to Our service plus any length of any relevant legal obligations.

Payment information

For the duration of the subscription to Our service plus any length of any relevant legal obligations.

Profile information including

For the duration of the subscription to Our service.

Technical information

For the duration of the subscription to Our service.

  1. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

  1. How Can I Control My Personal Data?
    • In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
  1. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Part 14 and Our Cookie Policy /cookie-policy.

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

  1. How Do You Use Cookies?

For more details, please refer to Our Cookie Policy.

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Stuart Brown):

Email address: dpo@childsafevpn.com.

Telephone number: 02081918528.

Postal Address: Child Safe VPN Ltd, Unit 9 The iO Centre, Skeffington Street, The Royal Arsenal, Woolwich, London SE18 6SR.

  1. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. we recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 01/09/2019.