Privacy Policy

We care about the privacy of your data and are committed to protecting it. This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information. We’ll also explain what choices you have with respect to the information.

This Privacy Policy applies to the:

• ClearVPN services (the “Services”, “Service” or “ClearVPN”) provided by MacPaw;
• ClearVPN content (the “Content”), which includes the ClearVPN website (the “Site”).

(WITH YOUR PERMISSION) Your Device ID. This information is required to provide you with a subscription to use our Service if you are willing to use the Service on several devices.

(WITHOUT YOUR PERMISSION) Anonymous VPN Connection Diagnostics and Crash Reports:

• Diagnostic information about if and how a VPN connection attempt failed;
• Speed test data;
• Crash reports, also without any personally identifiable information.

Information related to your account e-mail address (if you sign up via e-mail or via Single sign-on). This information is required to provide you with a subscription to use our Service when you decide to sign up via e-mail.

Successful connection (whether you have successfully established a VPN connection on a particular day (but not a specific time of the day), to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address)). This information assists us in providing technical support, such as identifying connection problems, providing country-specific advice about how to best use our Service, and to enable our engineers to identify and fix network issues.

Summary (minimal usage statistics). This information helps us to maintain quality of our Service.

Device-specific information like operating system version, language, device model. This information allows you to use several devices for the Services, allows us to differentiate between devices and control device management.

Your country (using IP). This information is needed to provide you with the most appropriate VPN Presets. We do not collect and save your IP address.

We guarantee a strict no-logs policy for our Services, meaning that our Service is provided by an automated process, and your activities while using it are not monitored, recorded, logged, stored, or passed to any third party. We do not store connection timestamps, session information, used bandwidth, traffic logs, IP addresses, or other data.

We’ve designed our Service so that it categorically eliminates storage of sensitive data. We may know that you have used ClearVPN, but we never know how you have utilized our Service. We stand by our firm commitment to your privacy by not possessing any data related to a user’s online activities.

ClearVPN does not knowingly collect personal information from children under the age of 13. If we determine we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 13, please do not submit any personal information through the Service or Content. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Service or Content without their permission.

ClearVPN uses cookies and similar technologies in our Service and/or Content that help us collect other Information. The Service or Content may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Site and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy. Specifically for the Services we use the third-party cookies with your permission using the following services: Facebook Conversion API, branchSDK, Pushwoosh, FacebookSDK, Appsflyer. To learn more about their usage, please visit the respective websites.

We keep records of any correspondence, questions, complaints, or compliments you submit to us through our Service or Content, along with our response. Depending on how you contact us, we may collect your email address and any additional information you provide to us. Having full correspondence records enables our staff to provide the best possible customer support experience.

Our Site may contain links to and from the websites that belong to third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy statements or policies and that we do not accept any responsibility or liability for these statements or policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Our Sites may also use or offer Services or services from third parties (including Developer Content). Information collected by third parties, which may include such things as location data or contact details, is governed by the applicable privacy policies provided. We encourage you to read the privacy policies of all such third parties and App Developers.

Information submitted to us will be transferred to, processed, and stored in the United States of America. We also process your personal data in Ukraine. Data stored and processed by ClearVPN may sometimes be moved between these zones (in a secure manner). If you post or transfer any information to or through our Service and/or Content, you are agreeing to such information, including personal data, being hosted and accessed in the United States and Ukraine.

As the general rule, we retain your data while you are a customer and will delete your information within 30 days of either party’s termination of the Terms of Use or upon written request. You can remove your personal data from ClearVPN at any time by emailing us with the respective request: [email protected]. However, we may keep some of your personal data for as long as reasonably necessary for our legitimate business interests or other purposes fulfilling requirements of the law, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

When you give us personal information, we take steps to make sure that it’s treated securely.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.

Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Service and/or Content.

We take the security of your data very seriously and work to protect your data from loss, misuse, and unauthorised access or disclosure.

All staff and officers who handle relevant data are aware of this policy and have been given training in how to correctly collect, process, store and delete data. We hold a log of when staff training was undertaken and update it on an annual basis.

All breaches will be reported to the relevant supervisory authority within 72 hours, unless the data was anonymised or encrypted or if it has a particularly high risk.

Breaches of this policy by our staff, contractors, officers will be dealt with under the MacPaw’s grievance and disciplinary policy and may lead to a disciplinary sanction.

If we learn of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site Depending on where you live, you may have a legal right to receive such notices in writing.

We committed to user privacy worldwide, and our existing practices reflect that through minimal collection of data and ensuring users have control over their personal information. The General Data Protection Regulation (GDPR) requires us to outline those practices in a specific manner for users in the EEA.

In line with the GDPR, we collect and process the data outlined in this Privacy Policy on one of the following bases, depending on the circumstances:

1. For the purposes of fulfilling our contractual obligations to users, including:

• Providing users with the Services and/or Content they have requested.
• Managing user subscriptions and processing payments.
• Providing customer support.

2. For a legitimate interest associated with the operation of our business, including:

• Enhancing the quality, reliability, and effectiveness of our Service and/or Content.
• Communicating with customers to provide information and seek feedback related to our Services and/or Content.
• With the consent of users, which users can withdraw at any time.

You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at [email protected].

If you’re a California resident, you may have some rights ((as defined in the California Consumer Privacy Act (“CCPA”)). Under the CCPA you have the right to:

• access the personal information we hold about you;
• know what personal data we have collected or disclosed about you;
• opt in or out of marketing, analytics, and other similar activities;
• equal services without discrimination;
• request deletion of the personal data we have about you.

You can exercise your rights under the CCPA to access, know, correct, delete or object to the processing of your personal information by contacting us at [email protected].

We may need to update this Policy to keep pace with changes in our Site, Product, and Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Site, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of our Service and/or Content after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to stop using the Service and/or Content.