Privacy Policy

This Policy regarding the processing of personal data (hereinafter — the Policy) defines the purposes and general principles of processing personal data of personal data subjects, as well as the measures implemented to protect personal data during their use of any of the services of the Website located at: https://vpn-naoborot.com/ (hereinafter — the Website).

The Policy is a publicly available document of the Operator and provides third parties with the opportunity to review it.

This Policy applies to all personal data that the Operator may receive from the User during the use of the Website and its services.

The Policy is effective indefinitely after approval and until it is replaced by a new version.

If the User disagrees with the terms of this Policy, the use of the Website must be terminated immediately.

1. General Provisions

1.1. The Operator of personal data is the Limited Liability Company "Hypersoft" (hereinafter — the Operator).

1.2. Processing of the User's personal data is carried out to achieve the purposes of processing personal data by any lawful means, including in personal data information systems with or without the use of automation tools (mixed processing of personal data). Processing of personal data of Users is carried out in accordance with Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data".

1.3. Consent to the processing of personal data is valid from the moment of its submission to the Operator until the date the Operator loses its legal status as a legal entity, or in the event such consent is withdrawn by the User.

1.4. Use of the Website's services constitutes the User's unconditional consent to the Privacy Policy and the conditions specified therein for processing their personal information; in case of disagreement with these conditions, the User must refrain from using the Website and its services.

1.5. The Operator has the right to make changes to the Privacy Policy without the User's consent. The new version of the Privacy Policy comes into effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.

Any changes to the Policy are made by the Operator independently and take effect on the day following the day such changes are published. The Operator notifies Users of changes to this Policy, including by publishing a new version of this Policy. The User undertakes to independently familiarize themselves with changes made to the Policy. Actual use by the User after changes to the terms of this Policy means the User's agreement with the new terms.

1.6. The text of the Privacy Policy is available to Users on the Internet at: https://vpn-naoborot.com/docs/privacy-policy.

1.7. The following terms and definitions are used in this Policy:

1.7.1. operator — a legal entity that, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, the actions (operations) performed with personal data;

1.7.2. personal data — any information relating directly or indirectly to a specific or identifiable individual (personal data subject); processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

1.7.2. automated processing of personal data — processing of personal data using computer technology;

1.7.3. distribution of personal data — actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way;

1.7.4. provision of personal data — actions aimed at disclosing personal data to a specific person or specific group of persons;

1.7.5. blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data);

1.7.6. destruction of personal data — actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;

1.7.7. personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing;

1.7.8. website (Site) — a set of graphic and informational materials, as well as programs for computers and databases, ensuring their availability on the Internet at the network address: https://vpn-naoborot.com/;

1.7.9. personal data permitted by the personal data subject for distribution — personal data, access to which by an unlimited circle of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided by the Law on Personal Data (hereinafter also — personal data permitted for distribution);

1.7.10. user — any visitor to the website https://vpn-naoborot.com/, who has logged in/registered on it;

1.7.11. provision of personal data — actions aimed at disclosing personal data to a specific person or specific group of persons;

1.7.12. distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way;

1.7.13. IP address — a unique network address of a node in a computer network built on the IP protocol.

1.8. If the Policy uses terms not specified in clause 1.7, they shall be used and interpreted in accordance with current legislation and business customs established on the Internet.

2. Principles and Conditions for Processing Personal Data

2.1. The processing of personal data is carried out by the Operator on the basis of the following principles:

2.2. legality and fair basis;

2.2.1. limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;

2.2.2. preventing the processing of personal data that is incompatible with the purposes of collecting personal data;

2.2.3. preventing the combination of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;

2.2.4. processing only those personal data that correspond to the purposes of their processing;

2.2.5. compliance of the content and volume of processed personal data with the stated purposes of processing;

2.2.6. preventing the processing of excessive personal data in relation to the stated purposes of their processing;

2.2.7. ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;

2.2.8. destruction of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these purposes, if it is impossible for the Operator to eliminate the violations of personal data, unless otherwise provided by federal law.

2.3. Personal data permitted for processing under this Policy is provided by the User when using the Website:

— user identifier stored in a cookie;

2.3.1. The Operator may process other personal data of the User that is necessary for the use of the Website.

2.3.2. Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life, is not carried out by the Operator.

2.3.3. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data are observed.

2.4. The purposes of processing personal data are:

2.5. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

2.6. The Operator has the right to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data provided for in Federal Law No. 152.

2.7. Depersonalized data of Users collected using Internet statistics services may be used to collect information about Users' actions on the site, improve the quality of the site and its content.

2.8. The legal basis for processing personal data is:

2.9. Periods of processing personal data

Storage of personal data must be carried out in a form that allows the personal data subject to be identified, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, party to which, beneficiary or guarantor of which is the personal data subject. Personal data of Subjects processed by the Operator is subject to destruction in the event of:

3. Measures Applied by the Operator When Processing Personal Data

3.1. When processing personal data, the Operator, at its discretion, takes the necessary legal, organizational and technical measures to protect them from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data, including:

3.2. Access to personal data processed by the Operator is granted only to persons whose official functions include working with such information and documents. The Operator transfers personal data to its employees in the manner established by the legislation of the Russian Federation, and limits this information only to those personal data that are necessary for the purposes of processing personal data.

3.3. The Operator has the right to provide access to the personal data of users in the following cases:

3.4. When storing personal data, the personal data operator is obliged to use databases located on the territory of the Russian Federation, in accordance with Part 5 of Art. 18 of the Federal Law "On Personal Data".

4. Rights and Obligations of the Parties

4.1. The personal data subject makes the decision to provide their personal data and gives consent to their processing freely, by their own will and in their own interest. Consent to the processing of personal data may be given by the personal data subject or their representative in any form that allows confirming the fact of its receipt, unless otherwise established by federal law.

4.2. The personal data subject has the right to receive information concerning the processing of their personal data, if such a right is not limited in accordance with federal laws. The personal data subject has the right to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.

4.4. The User has the right to:

4.4.1. receive information about the processing of their personal data;

4.4.2. clarify their personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or cannot be recognized as necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;

4.4.3. protect their rights and legitimate interests in court;

4.4.4. at their own discretion provide the Operator with personal data for processing on the terms specified in the Privacy Policy;

4.4.5. upon request receive from the Operator information concerning the processing of their personal data.

4.4.6. The User's right to access their personal data may be limited in accordance with federal laws, including if the User's access to their personal data violates the rights and legitimate interests of third parties.

4.5. The Operator is obliged to:

4.5.1. use the information received exclusively for the purposes specified in the Privacy Policy;

4.5.2. ensure the storage of confidential information in secret, not disclose without the prior written permission of the User, as well as not to sell, exchange, publish or disclose in any other possible ways the transferred personal data of the User, except as provided by the Privacy Policy;

4.5.3. take precautions to protect the personal data of the User;

4.5.4. block personal data related to the relevant User from the moment of the request of the User or their legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification in case of detection of inaccurate personal data or unlawful actions.

4.6. The Operator has the right to entrust the processing of personal data to another person on the basis of a contract concluded with this person, including a state or municipal contract.

The person processing personal data on behalf of the operator is obliged to comply with the principles and rules for processing personal data provided for by the Federal Law "On Personal Data".

In addition, if necessary, the operator has the right to transfer personal data to the bodies of inquiry and investigation, other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.

5. Scope and Categories of Processed Personal Data, Categories of Personal Data Subjects

5.1. The content and scope of processed personal data correspond to the stated purposes of processing. Processed personal data should not be excessive in relation to the stated purposes of their processing.

5.2. Processing of personal data is allowed in the following cases:

5.3. The categories of personal data subjects include:

5.3.1. Clients and counterparties of the operator (individuals) — Users of the Website;

In this category of subjects, the operator processes personal data received by the operator in connection with the conclusion of a contract to which the personal data subject is a party, and used by the operator exclusively for the execution of the said contract and the conclusion of contracts with the personal data subject:

— user identifier stored in a cookie;

6. Procedure for Destruction, Blocking of Personal Data

6.1. In case of detection of unlawful processing of personal data upon the request of Users, the Operator is obliged to block the unlawfully processed personal data related to these Users from the moment of such request for the period of verification.

6.2. In case of detection of inaccurate personal data upon the request of Users, the Operator is obliged to block the personal data related to these Users from the moment of such request for the period of verification, if blocking personal data does not violate the rights and legitimate interests of users or third parties.

6.3. In case of confirmation of the fact of inaccuracy of personal data, the Operator, on the basis of the information provided by Users or other necessary documents, is obliged to clarify the personal data within 7 (seven) working days from the date of submission of such information and remove the blocking of personal data.

6.4. In case of detection of unlawful processing of personal data carried out by the site, the Operator, within a period not exceeding 7 (seven) working days from the date of such detection, is obliged to terminate the unlawful processing of personal data.

6.5. If it is impossible to ensure the lawfulness of processing personal data, the Operator, within a period not exceeding 5 (five) working days from the date of detection of unlawful processing of personal data, is obliged to destroy such personal data.

6.6. The Operator is obliged to notify Users about the elimination of violations or about the destruction of personal data.

6.7. In case of achievement of the purpose of processing personal data, the Operator is obliged to terminate the processing of personal data and destroy the personal data within a period not exceeding 5 (five) days from the date of achievement of the purpose of processing personal data.

6.8. In case of withdrawal by Users of consent to the processing of their personal data, the Operator is obliged to terminate their processing and, if the storage of personal data is no longer required for the purposes of processing personal data, destroy the personal data within a period not exceeding 5 (five) days from the date of receipt of the said withdrawal.

6.9. In the absence of the possibility of destroying personal data within the period specified in clauses 6.4-6.8 of this Policy, the Operator blocks such personal data and ensures the destruction of personal data within a period of not more than 1 month, unless another period is established by federal laws.

6.10. Account deletion.The User has the right to request the deletion of their account directly in the Operator's mobile application: Settings (the gear icon on the main screen) → "Request Account Deletion" → confirmation of the request. The User is signed out of the account on their device immediately after the request is confirmed.

6.11. After the account deletion request is received, the account, the email address and the data associated with the account (sessions, VPN keys) are permanently deleted within a period not exceeding 30 (thirty) days from the moment of the request. Recovery of the deleted data is not possible.

6.12. Account deletion does not automatically cancel a subscription purchased through the App Store. The User manages and cancels the subscription independently in the Apple ID settings (Settings → Apple ID → Subscriptions).

6.13. After the account is deleted, the Operator may retain a depersonalized record of the fact and date of the account deletion, which does not allow the User to be identified, solely for responding to requests from authorized bodies and resolving possible disputes, as well as information whose retention is required in accordance with the legislation of the Russian Federation.

6.14. An account deletion request may also be sent to the Operator at the email address: team@vpn-naoborot.online.

7. Identification Files

7.1. Identification files and other technologies (hereinafter — cookies) may be used on the Website. Such technologies are used to analyze user behavior on the site and measure advertising effectiveness.

7.2. Cookies are necessary for the use of the Website, navigation on the Website and the correct operation of its services. The User can disable cookies in the settings of the web browser or mobile device used by them. In this case, it is possible to limit some functions of the website associated with the use of cookies.

7.3. Cookies may contain information about the User's actions on the Website, including the information entered by them, and are used in accordance with the provisions of the Privacy Policy. The data stored in these cookies is available only to the Website and cannot be used in any way when the User visits other sites.

7.4. By using the Website, the User agrees to the storage of cookies by the Website using the appropriate standard mechanism in the Internet browser on their computer/smartphone.

7.5. Users of the Website may be shown pop-up notifications about the collection and processing of cookie data with a link to the Policy and buttons for accepting the processing conditions or closing the pop-up notification. The user's acceptance of the cookie processing conditions or closing the pop-up notification in accordance with the Policy is regarded as consent to the processing of cookie data.

8. Dispute Resolution

8.1. Before going to court with a claim on disputes arising from relations between the User and the Operator, a claim is submitted (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of the claim, within 10 (ten) working days from the date of receipt of the claim, notifies the claim applicant in writing of the results of the consideration of the claim.

8.3. If no agreement is reached, the dispute will be submitted to court in accordance with the current legislation of the Russian Federation.

8.4. The current legislation of the Russian Federation applies to the Privacy Policy and the relations between the User and the Operator.

9. Final Provisions

9.1. Other rights and obligations of the personal data Operator are determined by the legislation of the Russian Federation in the field of personal data. Officials of the Operator (if any), guilty of violating the rules regulating the processing and protection of personal data, bear material, disciplinary, administrative, civil or criminal liability in the manner established by federal laws.

9.2. All information that is collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to independently familiarize themselves with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

9.3. All additional questions or suggestions regarding the Privacy Policy, as well as the processing of personal data, must be sent to the Operator's email address through the channels specified in the "Help" section: https://vpn-naoborot.com/help.

10. Contractor Details

Consent to the Processing of Personal Data

I hereby give my consent to the Limited Liability Company "Hypersoft", TIN: 9714065578 (hereinafter — the Operator), to process my personal data on the website at https://vpn-naoborot.com/(hereinafter — the Website) and its subdomains in accordance with the requirements of the Federal Law "On Personal Data" for the purpose of conducting a survey and providing services.

1. I accept all the terms of the Privacy Policy posted at: https://vpn-naoborot.com/docs/privacy-policy, and give my consent to the Operator to process, including automated (mixed method of processing personal data), personal data in accordance with the Federal Law "On Personal Data", including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, distribution, access), blocking, depersonalization, deletion, destruction of personal data.

2. When filling out electronic forms, I guarantee that my personal data is true and belongs to me.

3. Consent to the processing of personal data is given consciously and is unambiguous.

4. I am informed that I can withdraw this consent by providing the Operator with a statement in simple written form in accordance with current legislation of the Russian Federation.

5. I undertake to take measures to ensure the security and preservation of personal data, including those necessary for using the Website, such as using antiviruses, taking care of preserving passwords and making them inaccessible to third parties.

6. I undertake not to use other people's personal data when filling out electronic forms.

7. I give my consent to the processing of my personal data:

— user identifier stored in a cookie;

8. The purposes of processing personal data are:

9. By using the Website, I give my consent to the storage of cookies in accordance with the Privacy Policy using the appropriate standard mechanism in the Internet browser on the computer/smartphone.

10. In accordance with the Federal Law "On Personal Data" of 27.07.2006 No. 152-FZ, freely, by my own will and in my own interest, I express my consent to the collection, analysis, processing, storage and use, clarification, destruction of my personal data for purposes related to the use of the site, execution of the contract, participation in promotional events.

11. I express full and unconditional consent to the use of my data to maintain communication with me in any way, including sending emails to the specified email address for the purpose of informing about the receipt of new goods/services, notifying about ongoing promotions, events, discounts, their results, for conducting correspondence surveys to study opinions about goods/services, trade organizations, sending news, etc.

12. This consent is valid from the day of its signing until the day of withdrawal in written form.