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.
Our Terms of Service, including their limitation on liability, apply to this Policy. You can read them here.
B. Collection and Creation of 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.
- 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.
C. Categories of Personal Data
- 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
E. Purposes of Processing Data
- 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
- 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
- “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
- 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.