ABC-VPN is committed to protecting and respecting your privacy.
VPN Service Provider
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our websites you are accepting and consenting to the practices described in this policy.
For the purpose of the European Data Protection Regulations (‘GDPR’) and the Data Protection Act 2018 (the Act).
This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.
Information we may collect from you:
We may collect and process the following data about you:
Information you give us:
- When filling in forms on our website www.abcvpn.co.uk(“our site”) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our events and/or services, complete a survey, sign up to a newsletter, post material on our site, report a problem with our site, request further services. The information you give us may include your name, address, email address, phone number, and personal description;
- We may also collect information from you when you use other sites which we operate or support. In such cases, please refer to the privacy notice contained on such sites.
Information we collect about you:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), cookies and methods used to browse away the page and any phone number used to call our customer service number.
Information we receive from other sources:
- We may receive information from other sources, such as from our members, associate members, government officials, law enforcement and fraud prevention agencies, regulatory bodies, our other partners for the purpose of providing services to our members including supporting members and law enforcement and fraud prevention agencies to combat, prevent and detect economic criminal activity.
- The information received may include names, address, bank account details, transaction information, criminal convictions and cautions and indications of potential or actual criminal activity
- Offers and promotions to you via our site, any other websites we operate or other services we provide, advertising networks and analytics providers or publicly accessible data.
Uses made of the information
We use information held about you in the following ways:
- To carry out our obligations arising from any agreements entered between you and us and to provide you with the information, products and services that you request from us, including providing membership services to you; including events, training and working groups;
- To ensure that content from our site is presented in the most effective manner for you and for your computer or device or to provide you with content which we feel may interest you, where (if required to do so) you have consented to be contacted for such purposes:
- to allow you to participate in interactive features of our services, when you choose to do so; and
- to notify you about changes to our services.
As a business, it is critical that we perform our agreement with you with the best service possible, and it is in our legitimate interest to be responsive to you and to ensure the proper functioning of our products and organisation.
Information we receive from other sources:
We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter with [them or] you, including without limitation any data processor we engage.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transfers will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site: any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your rights under Data Protection Law
- We operate under the Data Protection Act 2018 (‘DPA’) and the European General Data Protection Regulation (‘GDPR’).
- The DPA and GDPR apply to ‘personal data’ we process, and the data protection principles set out the main responsibilities we are responsible for.
We must ensure that personal data shall be:
- Processed lawfully, fairly and in a transparent manner
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- Accurate and where necessary kept up to date
- Kept for no longer than is necessary for the purposes for which the personal data are processed. We operate a data retention policy that ensures we meet this obligation. We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For detail of our current retention policy contact our privacy officer at email@example.com
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.
In most cases we process personal data based on your contract with us. In other cases, we process personal data only where there are legitimate grounds for so doing.
To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.
We ensure data protection compliance across the organisation through:
- Implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies
- Maintaining relevant documentation on processing activities
- Implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third-party arrangements
Under the GDPR You have the following specific rights in respect of the personal data we process:
- The right to be informed about how we use personal data – This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK
- The right of access to the personal data we hold. In most cases this will be free of charge and must be provided within one month of receipt
- The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request
- The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The right to restrict processing, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue
- The right to data portability which, subject to several qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services
- The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task
Rights in relation to automated decision making and profiling
Please contact our privacy officer at firstname.lastname@example.org for more information about the GDPR and your rights under Data Protection law.
If you have a complaint about data protection at ABC VPN, please contact our privacy officer at the above email address.
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