Last updated: Dec 13th, 2022
Welcome
Security and privacy are at the heart of what
we do. Accordingly, we think it’s important to be transparent about what we do
with your information and how we handle it. This Privacy Policy describes
how we process and handle data provided to us in connection with your use of
our products, services, apps, and websites that link to this policy (we refer
to these collectively as our “services”).
This policy uses the term “personal data”
to refer to information that is related to an identified or identifiable natural
person and is protected as personal data under applicable data protection law.
Who are we?
This policy covers the data processing
practices of Tizi VPN and Absolute Tech Inc.
In this policy, “we,” “us,” and “our” refers
to the particular company from the list above that provides you with the
services and is responsible for handling your data in accordance with this
policy. For mobile apps, you can identify which company this is by looking at
which company is listed as offering the app on the download page for that app
or reviewing its terms of service.
1. What information do
we collect about you?
This section describes the various types of
information we collect from and about you. This information is not collected in
all situations, but only in specific situations. To understand the context in
which collection occurs, see Section 2 (How do we use your information?). More
information about some of the mechanisms we use to collect this information,
such as cookies, is available in Section 4 (Tracking Technologies &
Cookies).
1.1. Information you
provide to us
● Account information. Some services require or allow you to
create an account before you can access them. As part of registering for an
account, we may collect information such as your name, username, email address,
and password.
● Billing and payment information. In order to purchase a service, you may
need to provide to us with details such as billing name, billing contact
details (street addresses, email addresses), and payment instrument details.
● Identity verification information. Some services require you to verify your
identity as part of creating an account to access them. We may collect
information such as email addresses for this purpose.
● Communications and submissions. You may choose to provide us with
information when you communicate with us (e.g. via email for support or to
inquire about our services), including when you fill out an online form,
respond to surveys, provide feedback, participate in promotions, or submit
information through our services.
1.2. Information
collected when you use our services
● Usage information. We collect information about how you
interact with our services, such as how much bandwidth you use, and when and
for how long you use our services.
● Device information. We collect information from and about the
device you use to access our services. For example, we may collect device
identifiers, browser types, device types and settings, operating system
versions, mobile, wireless, and other network information (such as internet
service provider name, carrier name and signal strength), and application
version numbers.
● Diagnostic information. We may collect information about the
nature of the requests that you make to our servers (such as what is being
requested, information about the device and app used to make the request,
timestamps, and referring URLs). However, we do not log any information that
associates your identity with your VPN browsing activity. We do not maintain
any records that show what you were browsing or accessing through a VPN
connection.
● Location information. We may collect your location information
based on a variety of sources, such as your device’s GPS or by calculating an
approximate latitude and longitude based on your IP address.
1.3. Information
provided to us by third parties
● Referrals. If you are invited to use our service,
the person who invited you may submit your personal data, such as your email
address or other contact information.
● Third Party Accounts. Some services may allow you to register an
account using a third party account (such as an Apple or Microsoft account). If
you do so, that third party may send us some information about you that they
have. You may be able to control what information they send us via your privacy
settings for that third party account.
● Threat Information. We may receive information from reputable
members of the security industry who provide information to help us to provide,
develop, test, and improve our services (for example, lists of malicious URLs,
spam blacklists, phone number blacklists, and sample malware). Some of this
information may contain personal data on an incidental basis.
You generally do not have a duty to disclose
personal data to us unless you have a contractual obligation to us to do so.
However, we need to collect and process certain information that is necessary
or legally required in order to provide the services to you or otherwise
perform our contractual relationships with you.
We use the information we collect for various
purposes described below.
● To provide, maintain, troubleshoot, and
support our services. We
use your information for this purpose on the basis that it is required to fulfill
our contractual obligations to you. Examples: using information about how much
bandwidth you use and how long you use our services in order to provide the
services in accordance with a plan to which you have subscribed; using threat
and device information to determine whether certain items pose a potential
security threat; using location information to connect you to the nearest and
fastest VPN server; and using usage information to troubleshoot a problem you
report with our services and to ensure the proper functioning of our services.
● For billing and payment purposes. We use your information in order to perform
billing administration activities and process payments, which are required to
fulfill our contractual obligations.
● To communicate with users and prospective
users. We use
your information to communicate with you, including by responding to your
requests, and sending you information and updates about our services. We may do
this in order to fulfill our contract with you, because you consented to the
communication, or because we have a legitimate interest in providing you with
information about our services.
● To improve our services. We want to offer you the best services and
user experiences we can, so we have a legitimate interest in continually
improving and optimizing our services. To do so, we use your information to
understand how users interact with our services. Examples: we analyze certain
usage, device, and diagnostic information to understand aggregated usage trends
and user engagement with our services (and, for example, invest in technical
infrastructure to better serve regions with increasing user demand); we may use
device and threat information to conduct spam, threat, and other scientific
research to improve our threat detection capabilities; we review customer
feedback to understand what we could be doing better.
● To develop new services. We have a legitimate interest in using
your information to plan for and develop new services. For example, we may use
customer feedback to understand what new services users may want.
● To market and advertise our
services. We may
use your information to provide, measure, personalize, and enhance
our advertising and marketing based on our legitimate interest in offering you
services that may be of interest. Examples: we may use information such
as who or what referred you to our services to understand how
effective our advertising is; we may use information to administer promotional
activities such as sweepstakes and referral programs. Our VPN product does not
use your VPN browsing activity for these purposes and we do not maintain any
records that show what you were browsing or accessing through a VPN connection.
● To prevent harm or liability. We may use information for security purposes
(such as to investigate security issues or to monitor and prevent fraud) and to
prevent abuse. We may do this to comply with our legal obligations, to protect
an individual’s vital interests, or because we have a legitimate interest in
preventing harm or liability to us and our users. For example, we may use
account, usage, and device information to determine if an entity is engaging in
abusive or unauthorized activity in connection with our services.
● For legal and compliance. We internally use your information as required
by applicable law, legal process, or regulation. To learn about our practices
regarding sharing your information with third parties for
legal compliance purposes, see Section 3.1 below. We also use your information
to enforce our legal rights and resolve disputes.
3.
Who do we share your information with and why?
We may disclose your information in the
following circumstances:
● In accordance with your instructions or
consent. For
example, some services may allow you to register an account using a third party
account (such as an Apple or Microsoft account). If you choose to do so, we
will share information with the third party account provider.
● Affiliates and third party service
providers. To help
us provide some aspects of our services, we work with our affiliates and
trusted third parties. To protect your data, we have negotiated appropriate
confidentiality and data processing terms with these third parties, review
their security practices, and limit information sharing to the scope of what
they are helping us with. Examples of activities that third parties help us
with include:
○ processing customer payments
○ providing analytics about our services
○ providing sales and customer support
○ maintaining the infrastructure required to
provide our services
○ delivering our marketing and advertising
content
○ serving advertising content
● To a new owner. If ownership or control of all or part
of our services, assets, or business changes, we may transfer your information
to the new owner.
● Aggregated or de-identified data. We may use and share aggregated data and
data that is de-identified such that it no longer reveals the identity of an
individual user for regulatory compliance, research and analysis, our own
marketing and advertising activities and other legitimate business purposes.
● To comply with legal process and the law. We are fiercely protective of the
privacy of our users. For our VPN product, we protect your privacy by ensuring
that we do not log or record online activities that you conduct over a VPN
connection in any way that can be tied back to you, meaning that we do not have
any data to share with law enforcement and government agencies who make
requests for information about what you were doing through a VPN connection.
Subject to the foregoing, we may share your information if we are required to
do so by applicable law; to comply with our legal obligations; to comply with
legal process; and to respond to valid law enforcement requests relating to a
criminal investigation, or alleged or suspected illegal activity that may
expose us, you, or any of our other users to legal liability. If we share your
information for these purposes, we limit the information shared to what is
legally necessary, and challenge information requests that we believe are
unlawful, overbroad, or otherwise invalid.
● To enforce our rights and prevent fraud
and abuse. We
may share limited amounts of your information to enforce and administer our
agreements with customers and users, and to respond to claims asserted against
us. We may also share your information in order to protect against fraud and
abuse against us, our affiliates, users and others.
3.2. Displaying
Advertisements
We may serve ads to users in certain regions.
The ads we display in our services are supplied either by advertisers we have
relationships with or by third party advertising networks such as Apple Store.
To display third party ads in our apps, we integrate into them a software
development kit (SDK), which consists of software code provided by the ad
network.
We provide limited personal data about you to
such third party advertising networks to enable them to provide their services.
For example, some of these advertising networks may collect information through
their SDKs, such as your mobile advertising identifier, IP address, and device
information, for the purpose of serving you with “personalized” ads (ads that
they think are more relevant to you) and measuring your response to those ads.
If you are using a VPN connection, your IP address is hidden from ad networks
and replaced with the IP address of our VPN servers.
Each advertising network collects this
information according to their privacy policies. Where
an AdChoices logo appears on an ad, you can click it to learn more
about the ad network that provided the ad, its privacy policy, and your choices
regarding opting out from any personalized advertising. If you opt out from
personalized advertising, you may still see non-personalized ads.
While we request you not to use ad blockers to
prevent the display of third party ads because that is how we support our free
services, our services are able to continue functioning if you do use ad
blockers.
4.
Tracking Technologies & Cookies
4.1. About Tracking
Technologies
We use various technologies in our services to
help us collect information. For convenience, we refer to these as “tracking
technologies,” although they are not always used to track individuals and the
information collected is in a non-identifiable form that does not reference any
personal data. Tracking technologies include:
Cookies
Cookies are small portions of text that are
stored on the device you use to access our services. Cookies enable us (or third
parties that we allow to set cookies on your device) to recognize repeat users.
Cookies may expire after a period of time, depending on what they are used for.
Pixel Tags / Page Tags / Web Beacons / Tracking Links
These are small, hidden images and blocks of
code placed in web pages, ads, and our emails that allow us to determine if you
perform a specific action. When you access a page, ad, or email, or click a
link, these items let us know that you have accessed that page, opened an
email, or clicked a link.
SDKs
SDKs or software development kits are software
code provided by our business partners that let our software interact with the
services those partners provide. For example, in certain of our mobile apps, we
may use an SDK to enable our app to serve ads from an advertising network.
Sometimes these interactions will involve that business partner collecting some
information from the device on which the software is run.
We use cookies:
● To provide our services. Some cookies are essential for the
proper operation of our services. For example, cookies allow us to authenticate
who you are and whether you’re authorized to access a resource.
● To store your preferences. Cookies can store your preferences, such
as language preferences or whether to pre-fill your username on sign in forms.
We may also use them to optimize the content that we show to you.
● For analytics. Cookies are used to inform us how users
interact with our services so we can, as a legitimate interest, improve how
they work (such as what screens or webpages you access, and whether our
advertising is effective).
● For security. Cookies can enable us and our payment
processors to detect certain kinds of fraud.
● For advertising-related purposes. We advertise our services online with the help
of third parties who show ads and marketing about us on sites around the
internet.
We may allow our business partners to place
certain tracking technologies in our services. These partners use these
technologies for the following purposes:
● To provide our services. Some business partners who help us to
provide our services may use these technologies to support those efforts.
● For Analytics. To help us understand how you use our
services.
● For Marketing. To help us market and advertise our
services to you, including on third party websites. Cookies are used in
connection with this to measure the performance of our advertising, attribute
actions you take with our ads with actions you take on our services, deliver ad
retargeting (serving ads based on your past interactions with our services),
and target ads at similar audiences.
● To Serve Ads. Ad networks may use these technologies
to display ads which they think will be more relevant to you. For more
information, please see the “Displaying Advertisements” section above.
● Our Cookies: Most web browsers and some mobile
devices give you the ability to manage your cookie preferences, including
deleting cookies and blocking cookies from being set on those browsers or
devices. Visit the “help” section of your mobile device to understand what
controls it gives you over cookies. Note that deleting or blocking certain
cookies could adversely impact the proper operation of our services.