Privacy Policy For FREE VPN App & Services

This Privacy Policy was last updated on January 6, 2022
Table of Contents:

A. This Policy

This Policy explains how we collect and store (“Process”) Personal Data. The Policy applies to the information we collect about visitors (the “you”) to www.appdynamite.com (the “Site“) and subscribers (the “you”) to the FREE VPN service (the “Services” and “App”), which are owned and operated by Dynamite LLC (“Company”, “we”, “us” and “our”). For the purposes of this Policy, Company is the Controller. Terms used in this Policy are explained in Section I below.

From time to time, we may change or update this Policy, without prior notice to you. Your continued use of the Site or Services constitutes your acceptance of the then-effective Policy.

Our Terms of Service, including their limitation on liability, apply to this Policy. You can read them here.

If you have any questions regarding this Policy, the information that is collected, or GDPR request, contact details are provided in Section N below.

B. Collection and Creation of Personal Data

We collect Personal Data: directly from you, through the use of the App. How we obtain personal data:
  • You: This data is collected when you fill out a form on our website; subscribe to the VPN Service; when you contact us via email, chat, telephone, social media platforms, or by any other means; when you publicly submit reviews on forums, review platforms, or any other means.
  • Our Sites: This data is collected when you visit any of our Sites, our partner and affiliate sites, or interact with our advertisements.
  • Our App: This data is collected when you download, install, or use our Apps.
Why we obtain personal data:
  • Provisioning of Services. To create your account, collect payment for our Services, and administer accounts.
  • Operating and Improving the App. To identify Service performance issues, improve App performance, fix bugs, plan improvements to our App or to create new Apps.
  • Communications. To send you information about industry news, product updates, changes to any of our Sites or Apps, to send you offers made available by us, our affiliates, or our marketing partners and to respond to your requests for help and technical assistance.
We may also create Personal Data about you, such as records of your interactions with our customer service department or details of your payments to us.

C. Categories of Personal Data

You are not required to provide any personal data to browse our Site. If you wish to subscribe to our Services, you may need to provide an active email address and billing information.
We may Process the following categories of Personal Data about you:
  • The Site: We process aggregated anonymous personal data from Site visitors using cookies, pixels, and similar technologies, such as Google Analytics. Depending on your browser privacy settings the aggregated anonymous data may include: browser type, device type, operating system, average time spent on our site, pages visited on the site, interactions with our content or advertising, gender, age, language preference, and country. The focus of this data collection is to improve our Site performance and provide you with the best browsing experience. 
  • The App: We process aggregated anonymous data to improve the quality of our Apps and Services. The data collected may include: User’s device brand, device model, OS version, country, crash reports, session lengths, server usage, protocol, build version, UI interactions, API requests and response codes, and app build version. Our VPN applications utilize analytics tools, such as FireBase and Adjust to gather and report performance data anonymously. We respect the privacy of our customers and only use this aggregated anonymous data to diagnose crashes, identify bugs, optimize server performance, and provide you with the best App experience.

D. Sensitive Personal Data

We respect your privacy and do not seek to collect or otherwise Process your Sensitive Personal Data. If we ever need to Process your Sensitive Personal Data for a legitimate purpose, we would do so in accordance with applicable law.

E. Purposes of Processing Data

We may Process your Personal Data for the following purposes:
  • Provision of services: providing our Sites, Apps and services to you, as well as operating, managing and improving our Sites and our Apps, providing content through them to you, maintaining and improving them, and notifying you of changes to them.
  • Communications: communicating with you by any means you have provided to us.
  • Administrative matters: processing to support sales, finance, corporate audits, vendor management, legal compliance, and preventing and investigating breaches of policy or law.
  • Security: helping secure your Personal Data,
  • Legal proceedings: establishing, exercising or defending legal rights.

F. Lawful Bases for Processing Personal Data

We may rely on the following legal bases for Processing your Personal Data:
  • Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
  • Contractual necessity: We Process your Personal Data where the Processing is necessary in connection with providing contracted-for VPN services to you;
  • Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law;

Legitimate interests: We may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

G. Tools and Disclosure of Personal Data to Third Parties

We use third-party services to assist us with processing payments, fraud detection, improving website and app performance, app crash information, and email communications. We do not sell personal information to third parties. Additional information on the third-party tools can be found in the tables listed here

H. Definitions

  • “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
  • “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
  • “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
  • “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
  • “EEA” means the European Economic Area.
  • “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  • “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
  • “Sensitive Personal Data” includes data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
  • “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
  • “Site” means any website operated, or maintained, by us or on our behalf.

I. Data Security

We implement appropriate technical and organizational security measures to protect your Personal Data.
  • In the workplace: We use appropriate security measures to protect your personal information from loss, theft, misuse, or unauthorized access. All of our employees are kept up-to-date on these best practices. In addition, we restrict employee access to service administrative panels to only those who require such access in order to perform their job functions.
  • On the internet: We seek to safeguard your data. Where appropriate, we use encryption, access controls, passwords, and physical security measures to protect the information we collect and maintain about you against unauthorized access and disclosure. However, because the internet is an open system, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted using the internet.

J. Data Minimization and Retention

We take every reasonable step to limit the volume and minimize the retention period of the Personal Data that we Process.

K. Data Accuracy

We take every reasonable step to ensure that your Personal Data is kept accurate, up-to-date, and erased or rectified if we become aware of inaccuracies.

L. Your Legal Rights

Under and subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

M. Contact Details

Please contact us at dynamite.llc.apps@gmail.com to submit a Data Subject Access Request; to submit a Data Subject Erasure Request; to exercise other rights regarding your data; to provide any comments, questions or concerns about any of the information in this Policy; or to raise any other issues regarding the Processing of Personal Data carried out by us. Your request will be routed to our privacy team.
You may also contact us as follows:

N. International transfer of Personal Data

To provide you with the Services under your contract, it is necessary for us to store, process and transmit your personal data in the United States and other locations around the world. These countries may have data protection laws that are different to the laws of your country.
When we process the data within our group, regardless of where we are, we have implemented appropriate safeguards to ensure your personal data will remain protected.

O. California Consumer Privacy Act Addendum

In accordance with the California Consumer Privacy Act, if you are a consumer residing in California these additional terms, found here, apply to you.