At Private Pipe Ltd™ our aim is to be open, honest and transparent about what happens to our customer’s data.
Your mobile cell and Wi-Fi data together with your location is captured by us and presented in easy to understand reports, accessed by you via our App.
In providing Private Pipe Free VPN™, we will:- · serve the occasional tailored advertisement from our partners based on your mobile usage patterns and / or location. We want this to become a service rather than a nuisance, but if you do not want to receive such adverts you can stop using and delete the App at any time. · share with our service partners data that has had all personal identifiers removed. This means we remove all an individual’s identifiable attributes so that they are anonymous and then aggregate multiple users together so as to protect your identity and privacy. We do not share individual customer information and you cannot be identified by this data.
The information we collect
Personal information. We collect your email or Facebook or twitter details together with your chosen registration password for Private Pipe Free VPN™. This enables us to identify you, ensure we present your data usage reports only to you and allows us to let you know about service enhancements or issues.
Device information. When you install or update Private Pipe Free VPN™ we will record the device hardware make and model as well as the operating system version.
Data usage. As part of the process of reporting to you your individual data consumption, we capture the timing and amounts of data consumed by each application and web page visited as well as the GPS location and connection type (cell or Wi-Fi).
Protecting your personal data
When using Private Pipe Free VPN™, all data traffic is encrypted and travels through our secure VPN tunnel. We use our own servers, not public or shared cloud servers. Personal details are stored separately from cell / Wi-Fi usage data. Additionally, multiple levels of security provide protection against unauthorised access to data usage records and the data you receive or send.
B. In Legal Language
For the purpose of the UK legislation regarding privacy and data protection, the data controller is Private Pipe Limited™ of Honingham Thorpe Business Park, Norwich Road, Colton, Norfolk, UK. Private Pipe Limited™ is registered as a data controller with the Information Commissioner’s Office (the supervisory authority in the UK responsible for data protection) with registration number: Z2643965.
1. Information we may collect from you
1.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
1.2. In order to provide the Private Pipe Free VPN™ service to you and to develop and improve the Licensed Application in accordance with our legitimate interests we may collect and process the following personal data about you:
1.2.1. Information that you provide by filling in forms in the Licensed Application or on our site https://www.privatepipevpn.com (oursite). This includes personal data provided at the time of registering to use our Licensed Application, subscribing to our service or requesting further services and updates, namely your email address and chosen password for the Licensed Application (unless you sign in with a social media account in which case we do not collect your login details). We may also ask you for personal data, namely your name and contact details, if you report a problem with our Licensed Application or site.
1.2.2. If you contact us (for example by email), we may keep a record of that correspondence and will collect your contact information only for the purpose of dealing with and responding to your correspondence.
1.2.3. Information relating to the websites you are accessing through the Licensed Application and your data usage including, but not limited to, session durations, page impressions, traffic data, location data, weblogs and other communication data, the domain name, video usage, and the date and time the information is logged, so that we can provide you with the data usage reports available in the Licensed Application, helping to improve and enhance the services offered by Private Pipe Ltd™, fraud detection & prevention and connecting you to the most efficient VPN servers relevant for your mobile operator and/or location. You can, if you wish, change your settings on your mobile device to limit the data that we capture such as disabling location data.
1.2.4. Information relating to your use of the Licensed Application, including your location data (where you have given your permission), the type of mobile device you use, and details of your mobile operator, for the purpose of helping to improve and enhance the services offered by Private Pipe Ltd™, fraud detection & prevention and connecting you to the most efficient VPN servers relevant for your mobile operator and/or location.
1.2.5. Information relating to the type and consumption of data used by your mobile device, including for example the number of applications used, the volume of email, the number of images websites contain, the data consumption of social media applications and websites and volume of video data, so that we can provide you with the data usage reports available in the Licensed Application, helping to improve and enhance the services offered by Private Pipe Ltd™, fraud detection & prevention and connecting you to the most efficient VPN servers relevant for your mobile operator and/or location. Please be assured that this information does not in any way provide us with access to view your emails or the content of your social media account.
1.2.6. Information about your computer or mobile device, including where available your IP address, operating system and browser type, for the purpose of fraud detection & prevention and providing the correct service applicable to your device type.
1.2.7. Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access, so that we can administer and protect our site (including troubleshooting, data analysis, testing, system maintenance, support, and reporting/hosting data) and for the purpose of network security and fraud prevention.
1.2.8. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them, and the information you provide in response to that survey will be retained by us for the purpose of studying how our customers use our site and the Licensed Application and to develop our products and services and grow our business.
1.2.9. Information relating to your IP address, general information about your browser and the operating system of your mobile device, the cookie number, and the date, time and duration of the usage will be logged each time you access websites, social media or other data through the Licensed Application, so that we can provide you with the data usage reports available in the Licensed Application, helping to improve and enhance the services offered by Private Pipe Ltd™, fraud detection & prevention and connecting you to the most efficient VPN servers relevant for your mobile operator and/or location.
1.3. If you apply for an employment opportunity with us, your application will contain personal data including your identity, contact details, and education and employment history. We will process this personal data in order to evaluate the merits of your application in accordance with our legitimate interests.
2. How we collect your personal data
2.1. We use different methods to collect data from and about you including through:
2.2.1 Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register to use the Licensed Application, subscribe to our services, request information from us, participate in a survey, or give us some feedback.
2.2.2 Automated technologies or interactions: As you interact with the Licensed Application or our site, we will automatically collect technical data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on your computer or mobile device) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
3.1. Our site uses analytical cookies to distinguish you from other users of our Licensed Application and our site. This assists us in the tracking of how users engage with our website, to provide you with a good experience when you browse our site and also allows us to improve the Licensed Application and our site. We use applications such as Google Analytics for monitoring our site & Mixpanel & AppsFlyer to identify things such as user retention figures which aids in our marketing efforts.
3.2. By using cookies, we may offer services tailored directly to you. A cookie is a text file saved on your computer or mobile device via your web browser. The cookie allows your computer or mobile device to be recognised and find out details about your previous visits to our site.
3.3. Users of advanced browsers such as Firefox, Opera and Safari can easily control their cookies to allow the best browsing response with high security, users of Internet Explorer 7 or lower should upgrade to Internet Explorer 8 (or higher) or an advanced browser for their own security and reliability of browsing. If you elect not to receive our cookies, you may find some functions of our site do not function or function unpredictably.
4.How we protect and store your personal data
4.2.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
4.2.2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
4.2.3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
4.3. Where we have given you (or where you have chosen) a password which enables you to access the Licensed Application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and to change this regularly.
4.4. When using the Licensed Application, internet traffic from your mobile device will be routed through our Private Pipe Ltd™ servers. We will do our best to protect your personal data using reasonable computer security safeguards but transmission of information via the internet or telecommunications networks can never be completely secure and we cannot guarantee the security of your personal data over the internet or telecommunications network; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
4.5. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data can be requested by contacting our data privacy manager.
4.6. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. How we use your personal data (purpose of processing)
5.1. In order to allow us to perform our contract with you and/or where we have a legitimate interest in doing so, we may process the personal data held about you for the following purposes:
5.1.1. to provide you with our site, the data management and other services accessed through the Licensed Application;
5.1.3. to ensure that content from our site is presented in the most effective manner for you and your computer or mobile device;
5.1.4. to personalise your use of the Licensed Application / our site and develop the design and style of the Licensed Application / our site to improve the services provided to you;
5.1.5. to monitor your data usage to provide you with estimated statistical analysis of your usage in the reports available in the Licensed Application;
5.1.6. to inform you about the latest changes to the Licensed Application / our site, or products, services or promotional offers that you might find interesting, where we have a legitimate interest in doing so, which may be notified to you by way of pop-up banners or notifications within the Licensed Application (save where pop-up banners and notifications have been disabled), by email or within your browser;
5.1.7. to provide you with information, products or services that you request from us, or respond to any other enquiry or request that you send to us;
5.1.8. to allow you to participate in interactive features of our service, when you choose to do so;
5.1.9. to maintain, manage and improve our site and the Licensed Application either ourselves or via third party suppliers;
5.1.10. to compile customer reviews where they have been submitted to us (provision of reviews is always voluntary);
5.1.11. to conduct market research (participation is always voluntary);
5.1.12. to carry out statistical, technical and logistical analysis to monitor data usage trends across different user groups and types of media;
5.1.13. to perform our contract with you, including any contract we are about to enter with you;
5.1.14. where we need to comply with a legal or regulatory obligation including the prevention of crime; and
5.1.15. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
5.2. We do not disclose personal data to our advertisers, but we may provide them with Aggregated Data about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such Aggregated Data to help advertisers reach the kind of audience they want to target (for example, women in a London postcode or New York Zip code). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
5.3. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.4. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosure of your information
6.1. We may disclose your personal information to third parties in the following circumstances, where we have a legitimate interest in doing so or where it is necessary for our performance of our contract with you or where we are legally obliged to do so:
6.1.1. It may be necessary for us to employ other companies and individuals with specialist skills to perform functions on our behalf. Whilst we will restrict any access to your personal data to such information as is needed to provide the service and will review the data security procedures of any supplier we may use, in order for the supplier to provide its function it may be necessary for them to have access to the servers containing your personal data. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our suppliers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6.1.2 In the event that 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 as part of the sale or purchase process and to allow this transaction to proceed.
6.1.3. If Private Pipe Ltd™ or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6.1.4. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our End User Licence Agreement and other agreements; or to protect the rights, property, or safety of Private Pipe Ltd™, our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. Your rights
7.1. You have legal rights in relation to your personal data, as follows:
7.1.1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
7.1.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
7.1.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
7.1.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
7.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
7.1.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7.1.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our services to you. We will advise you if this is the case at the time you withdraw your consent.
7.2. You can exercise the rights referred in clause 6.1 at any time by contacting our data privacy manager at Private Pipe Ltd™ Limited, Honingham Thorpe Business Park, Norwich Road, Colton, Norfolk, NR9 5BZ or by email to mailto:firstname.lastname@example.org 7.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
7.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
7.5. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
7.6. We will not disclose your individual data to any third party for marketing purposes but reserve the right to disclose Aggregated Data to any third party for marketing or other purposes. This will be anonymous statistical data about our users' use of the Licensed Application, data usage and patterns, and does not identify any individual.
8. Third Party Links
Our Licensed Application or site may, from time to time, contain links to and from the websites, plug-ins or applications of our partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. If you follow a link to any of these websites, plug-ins or applications please note that they will 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.
Private Pipe Limited™, Honingham Thorpe Business Park, Norwich Road, Colton, Norfolk, NR9 5BZ
You have the right to make a complaint at any time to the Information Commissioner's Office (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.