HotSpot VPN Privacy Policy Modified: September 05, 2017 Welcome, and thank you for your interest in Hotspot VPN’s Service. This Privacy Policy (this “Policy”) is displayed (collectively, together with the Service granted, our “Service”). This Privacy Policy describes what information is collected by us from any user of our Service (collectively or individually "User(s)"), as well as our use and disclosure of that information. This Policy generally describes the information that we gather from you on the Service, the ways in which we use and disclose this information, and the steps we take to protect this information. By using the Service, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Hotspot VPN Terms of Use. Capitalised terms used but not defined in this Policy have the meaning given to them in the Hotspot VPN Terms of Use. Our Commitment to User Privacy: Except as explained in this Policy, HotSpot VPN does not collect any Personal Information about you when you use the Service. “Personal Information,” also referred to as personally identifiable information, is information that may be tied to a specific individual. Examples of Personal Information include name, email address, mailing address, mobile phone number, and credit card or other billing information. Please note, however, that for purposes of this Privacy Policy, Hotspot VPN does not include your IP address or unique device identifier within the definition of Personal Information. Hotspot VPN’s practices regarding IP address and unique device identifiers are described separately in this Policy. If you purchase Hotspot VPN Subscription Service, you will be required to provide certain Personal Information to a third party Payment Processor (Such as Apple Payment Process). The Personal Information you provide in connection with your purchase of the Subscription Service of Hotspot VPN is not associated with your online activities when you use Hotspot VPN. Additionally, when you use the Service, Hotspot VPN will check your account information (which includes Personal Information) to determine the level of service you have signed up for before establishing your VPN connection. Your account information is not associated with your online activities when using Hotspot VPN. Our Commitment to Web Security: Hotspot VPN employs certain techniques and technologies intended to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please note that the Service does not protect your computer from viruses or malware. We recommend that you obtain and use anti-virus/anti-malware solutions and keep them up to date. The Information We May Collect: User-provided Information. In connection with the Service (such as in user forums or when registering for an account), you may provide us with various information, including Personal Information. You may also submit Personal Information in connection with purchasing Hotspot Subscription Service, which is collected through a company providing a payment mechanism (e.g., a payment processor, Apple’s iTunes, or a similar means of payment) (each, a “Payment Processor”) and is retained by the Payment Processor. You may also provide us with certain email account related information, such as account and credential information, which we use to enable faster sign-in by allowing pre-population of account log-in credentials when you access certain features of our Service. Your Personal Information is not associated with your online activities when you are using Hotspot VPN it does not require you to provide us with your Personal Information unless you decide to upgrade to Hotspot Subscription Service or to register for an account. "Automatically Collected" Information. When you use our Service, we may automatically record certain information from your web browser by using different types of proprietary technology (such as cookies), which may include your IP address or unique device ID. For example, we may collect your IP address when you commence your use of the Service; we do not, however, store logs associating your IP address with your online activities that take place when you are using of the Service. The automatically-collected information is used by Hotspot VPN only in the aggregate, in truncated form, or in order to generate a “hashed” or “virtual” IP Address. Hotspot VPN may use automatically-collected information to identify your general location, improve the Service, or optimize advertisements displayed through the Service. When Hotspot VPN Discloses Information: Except as described in this Policy, we will not disclose information that we collect in connection with your use of the Service to third parties without your consent. Please remember that, although Hotspot VPN assigns a unique identifier to each user of the Service, Hotspot VPN does not tie your unique identifiers to Personal Information about you, and all browsing information or other similar information relating to your online activities transmitted by you to our servers when using Hotspot VPN is cleared after your VPN “session” is closed. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances: Hotspot VPN may share anonymous or aggregated data with third parties, including its affiliates, advertisers, and other current and prospective business partners. Hotspot VPN may use anonymous or aggregated data collected for website administration, advertising, and promotional purposes, and may share such information with affiliated and unaffiliated entities. Hotspot VPN may provide Personal Information to third-party service providers who work for Hotspot VPN and who may contact you to notify you of occasional updates or other information relevant to our Service. Hotspot VPN may disclose automatically collected and other aggregate non-Personal Information with interested third parties to assist such parties in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on the Service. Hotspot VPN may disclose any information, including Personal Information provided by you, if required to do so by law or in the good-faith belief that such disclosure is necessary to comply with state, federal, or international laws (such as export control, copyright or criminal laws), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. Hotspot VPN also reserves the right to disclose any information, including Personal Information provided by you, that we believe in our sole discretion is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others. Information about our users may be disclosed and otherwise transferred to a potential or actual acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Third-party Advertisers and Web Sites: Hotspot VPN allows other companies, called third-party ad servers or ad networks, to serve advertisements within the Service. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on the Service. Any third parties, including advertisers, may automatically receive a virtual, proxy IP Address assigned to your device by Hotspot VPN when you are using HotspotVPN on protected sites. Your original IP address will not be permanently stored or provided to any third parties by your use of Hotspot VPN. As described in our Terms, however, we may not provide a virtual IP Address for every web site you may visit and third-party web sites may receive your original IP address when you are visiting those web sites. Third-party ad networks may also use other technologies (such as cookies, javascript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content, and may collect information about your online activities over time and across different web sites when you use our Service. This may include rough geographical data, data relating to the frequency at which advertisements are shown, whether you are a unique viewer of an advertisement or user of a web site, the domain on which the advertisement was shown, whether the advertisement was in view on your screen and whether you engaged with or clicked on the advertisement. Advertisers may also be able to obtain data that you willingly submit after clicking on the advertisement or through the advertisement itself, and advertisers may be able to link certain information about your web-viewing habits while using the Service by cross-referencing existing cookies or other data about you. This Policy does not apply to, and we cannot control the activities of third parties, such as advertisers or other web sites visited by Users. Please note that this Policy will not apply to your activities or any information you disclose directly to any third party, while using any third-party products or services, or while otherwise interacting with third parties. How third parties handle and use Personal Information related to their sites and services is governed by their security, privacy and other policies, if any, and not this Policy. Hotspot VPN has no responsibility for any third party's policies, or any third party's compliance with them. Your California Privacy Rights: Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Policy and our privacy commitments to our customers should not hesitate to contact us at [email protected] Changes and Updates to this Hotspot VPN Privacy Policy: Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Service, and indicate the date of the latest revision. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you in advance of the change (e.g., through prominent Policy on the Service, via contact information you may have provided to us, or through other reasonable means).