This privacy policy ("Privacy Policy" or "Policy") sets forth the privacy practices of ITehno SP (hereinafter called "VPN Tube") and applies to users ("user(s)" or "you") of all VPN Tube Products. The Policy explains the privacy rules applicable to personal data and other information collected or submitted when you access, install, or use VPN Tube Services and Websites regardless of the device (computer, mobile phone, tablet, etc.) you use.

1. Information We Collect

By accessing or using "VPN Tube" or "VPN Tube PRO" applications ("Applications") or other VPN Tube services ("Services"), you do not have to give VPN Tube any personally identifiable ("personal") information to browse our sites or use our Applications. In general, we collect the following limited information from users:

• Account Information. We may have access to your advertiser (device) ID. Also, if you chose to provide such information to VPN Tube to create a Premium account we will require to have access to your e-mail/username and password.
• Applications and Website Visitors. We do not collect any personal information from visitors to our Applications. We may have access to your advertiser (device) ID. For more information, see the "Cookies" section below. We do not track user activities outside of our Applications, nor do we track the browsing activities of users who are logged into our VPN service.

VPN Tube does not collect or log any traffic or use of its Applications or Services.

2. How We Use Your Information

We do not sell or rent personal information to others.

The information we collect through our Applications and Services is primarily used to create new accounts, collect payment for our Services, identify and communicate with current subscribers, or offer troubleshooting or customer support. We may also use personal information for the following reasons:

• To verify your identity when you login to the Applications or Service;
• For internal record keeping;
• To complete your in App purchase;
• To administer and improve our Applications and Services;
• To target our Applications content to your preferences;
• To respond to your requests or inquires and for other customer service purposes;
• So that we may periodically send you promotional information that we think may interest you, about products, services, and offers made available by us, our affiliates or our marketing partners; and
• To analyze usage and trends on our Applications and to better understand how users use the Applications and Services.
• Service Providers.With third party service providers who provide services on our behalf, such as processing payments, hosting our Applications, and sending email messages for us. Our service providers receive only the information they need to perform their designated functions, and are not permitted to use or disclose this information for their own marketing or other purposes;
• Aggregate, Anonymous or De-Identified InformationWe may have access to your advertiser (device) ID. Also, if you chose to provide such information toVPN Tube to create a Premium account we will require and have access to your e-mail/username and password.

3. Cookies

This section describes the information we collect about visitors to our Applications. As noted above, we do not track user activities outside of our Applications, nor do we track the web activities of users when they are logged into our VPN Services.

We may use or engage others to use cookies, clear gifs, and similar technologies to understand how users access and use our Applications. In general, you can browse our Applications without telling us who you are or submitting any personal information.

Browser Cookies. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. There are two types of cookies: session-based and persistent-based cookies. Session cookies exist only during an online session; we use session cookies to allow our systems to uniquely identify you while you are logged in to your account at the Applications. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies on the website only, to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Applications visitors who disable their web browsers' ability to accept cookies will be able to browse the Applications but certain Applications features will not function.

Third Parties. We may engage third parties, such as Google Analytics or Firebase, to track and analyze non-personally identifiable Applications data. We do not provide these third parties with any personal information that we have collected about you.

Use the following link to opt out of Google's Analytic tracking: https://tools.google.com/dlpage/gaoptout

4. Security Measures We Have In Place

We use security measures that are consistent with industry standards to protect your personal information from loss, theft, misuse or unauthorized access or disclosure or destruction. All employees and service providers are up-to-date on our security and privacy practices. In addition, access to user or subscriber personal information is restricted to those who need to know such information to perform their job functions.

Where appropriate, we use encryption, access controls, passwords, and/or physical security measures to protect the personal information we collect and maintain about you against unauthorized access and disclosure. Despite our efforts, no data security methods guarantee 100% protection. We do not promise and cannot guarantee that your personal information can never be viewed and/or used by others.

5. Emails

We may send you marketing and promotional emails about products, services and other information we think may interest you. You may unsubscribe/opt out from such emails at any time by selecting the opt out button to "unsubscribe" from marketing emails. In addition, if you receive a marketing or promotional e-mail from us, you may click the unsubscribe link contained in the e-mail to "opt out" of receiving future promotional e-mails from us. However, we may continue to send you emails about your account and for other customer-service-related purposes.

6. International Users

VPN Tube's servers are based in the European Union, so your personal information, if any, will be processed by VPN Tube in the European Union, where data protection and privacy regulations may be different than in other parts of the world. When you use our Applications with us from outside the European Union, you agree to the terms of this Policy and our Terms of Service, and give your consent to the transfer to and processing of such information in the European Union, which may not offer an equivalent level of data protection as that in the United States, Canada or other countries.

7. Changes to this Policy

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Applications and the most popular features or services accessed. This information does not contain any personal information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.

8. Enforcement

We regularly review our compliance with this privacy policy. When we receive a formal written complaint, it is our policy to contact the complaining party regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved by an individual and us.

9. No Rights of Third Parties

This privacy policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Applications.

10. No Error Free Performance

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy. The laws of Cyprus shall, to the extent applicable, govern this privacy policy.

11. Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at toactive.inc@gmail.com

12. Your Rights Related to Your Personal Information

Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose and that is related to you, including the right

• to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
• to rectify inaccurate Personal Information concerning you (right to data rectification);
• to delete/erase your Personal Information (right to erasure/deletion, right to be forgotten);
• to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability);
• to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object);
• in some cases, to restrict our use of your Personal Information (right to restriction of processing).

If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer able to use several functionalities of our Website and our services.

You may, at any time, send us an e-mail at toactive.inc@gmail.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.