1. An overview of data protection
Data collection when using the VPN connection
Perfect Privacy’s technical infrastructure has been designed and built with the requirement to collect only the absolute minimum of data necessary to operate the servers.
Specifically, we do not record or log any user traffic so potential sharing such data with third parties is technically impossible. We do not store IP addresses, access times or duration, nor bandwidth caused by individual users.
For the operation of the servers, displaying general server information on the website and for the detection and elimination of potential technical problems, we record the total load of the individual servers. No conclusions about a user’s identity can be drawn from this data.
For billing purposes and customer support, we store the following account-specific data:
- Login credentials
- expiry date of the account
- Email address (anonymous email providers are allowed)
We do not store payment information such as credit card details. These are processed exclusively by the payment service providers (see point 7, “Payment service providers”).
Data collection on our website
Who is responsible for the data collection on this website?
The data collected on this website are processed by the website operator. The operator’s contact details can be found in the required legal notice on our website.
How do we collect your data?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form.
Other data are collected automatically by our IT systems when you visit the website. This data is primarily technical data such as the browser and operating system you are using or when you accessed the page. The data is collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.
What rights do you have regarding your data?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
Analytics and third-party tools
You can object to this analysis. We will inform you below about how to exercise your options in this regard.
2. General information and mandatory information
The base of our business model is to principally avoid the storage of data!
When using Perfect-Privacy VPN, no personal user data such as IP addresses are collected. Only the login credentials, payment information and configuration settings are being held.
The base for data processing is Art. 6 par. 1 lit. b GDPR, which stipulates the processing of data to fulfill a contract or for pre-contractual purposes measures is permitted.
Our website unfortunately wouldn’t work without any data storage whatsoever.
We therefore recommend the use of Perfect Privacy VPN to use on our and other websites.
Please note that data transmitted via the Internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
Notice concerning the party responsible for this website
The party responsible for processing data on this website is:
VECTURA DATAMANAGEMENT LIMITED COMPANY
Phone: +41-41-511-52-54 (no support!)
Email: firstname.lastname@example.org (no support!)
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).
Revocation of your consent to the processing of your data
Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
Right to file complaints with regulatory authorities
In the event of data protection violations, the person concerned has a right of appeal to responsible supervisory authority. Responsible supervisory authority in data protection law Questions should be addressed to the data protection officer of the country in which our company is based.
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Phone: + 41 31 322 43 95
Fax: + 41 31 325 99 96
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
Encrypted payments on this website
Payment transactions after conclusion of a chargeable contract are processed via an encrypted SSL or TLS connection directly with our payment service provider Paymentwall.
In the case of encrypted communication, your payment data that you transmit cannot be read by third parties.
Information, blocking, deletion
As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.
3. Data protection officer
Voluntary appointment of a data protection officer
We have appointed a data protection officer for our company (especially for our customers within the scope of GDPR).
Phone: +49-40-4807473 (limited availability by telephone, no support!)
Email: email@example.com (no support!)
Our data protection officer is a member of German Association for Data Protection and Data Security (GDD).
4. Data collection on our website
Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
Server log files
The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
Registration on this website
You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.
To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.
We will process the data provided during registration only based on your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.
Posts and comments in our forum
When using our forum, in addition to your contributions and comments also details at the time of the creation of the comments, your e-mail address and your selected user name.
Subscribing to the comment feed
As a user of this site, you can sign up to receive the comment feed after registering. Your email address will be checked with a confirmation email. You can unsubscribe from this function at any time by clicking the link in the emails. The data provided when you subscribed to the comments feed will then be deleted, but if you have submitted this data to us for other purposes or elsewhere, it will be retained.
How long comments are stored
The comments and the associated data are stored and remain on our website until the content commented upon has been completely deleted or the comments are required to be removed for legal reasons (slander, etc.).
The comments are stored based on your consent per Art. 6 (1) (a) GDPR. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
Processing of data (customer and contract data)
We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.
Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
Data transferred when signing up for services and digital content
We will only transfer personal data to third parties if this is done within the framework of the contract processing is necessary, e.g. for payment processing and within the framework of our affiliate program. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.
The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
5. Analytics and advertising
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Objecting to the collection of data
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics.
Outsourced data processing
We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Demographic data collection by Google Analytics
This website uses Google Analytics’ demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section “Refusal of data collection”.
Google Analytics Remarketing
Our websites use the features of Google Analytics Remarketing combined with the cross-device capabilities of Google AdWords and DoubleClick. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.
This feature makes it possible to link target audiences for promotional marketing created with Google Analytics Remarketing to the cross-device capabilities of Google AdWords and Google DoubleClick. This allows advertising to be displayed based on your personal interests, identified based on your previous usage and surfing behavior on one device (e.g. your mobile phone), on other devices (such as a tablet or computer).
Once you have given your consent, Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that signs in to your Google Account can use the same personalized promotional messaging.
To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.
You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account; follow this link: https://www.google.com/settings/ads/onweb/.
The aggregation of the data collected in your Google Account data is based solely on your consent, which you may give or withdraw from Google per Art. 6 (1) (a) GDPR. For data collection operations not merged into your Google Account (for example, because you do not have a Google Account or have objected to the merge), the collection of data is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing anonymous user behavior for promotional purposes.
Google AdWords and Google Conversion Tracking
This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (“Google”).
As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Cookies are small text files that your internet browser stores on your computer. These cookies expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page.
Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not obtain any information that can be used to personally identify users. If you do not want to participate in tracking, you can opt-out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings. In doing so, you will not be included in the conversion tracking statistics.
Conversion cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
Post Affiliate Pro
Affiliate partners are third parties who use our service Perfect Privacy VPN and receive a commission for it. To control our affiliate program we use Post Affiliate Pro of the Quality Unit, LLC 3616 Kirkwood Highway, Suite A #1130 Wilmington, DE 19808, USA.
6. Plugins and tools
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.
If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.
7. Payment service providers
On our website we offer payment via payment wall. The provider of this payment service is Paymentwall Global HQ in 255 9th St, San Francisco, CA 94103, USA (hereinafter “Paymentwall”).
If you select payment via Paymentwall, the payment data you enter will be transmitted to Paymentwall. Your data will be transmitted to Paymentwall on the basis of Art. 6 para. 1 lit. a GDPR (consent) and Art. 6 Para. 1 lit. b GDPR (processing for the purpose of compliance with of a contract).
8. Cyber attacks
In the event of attacks on the security, integrity or availability of our data processing systems, we store everything that we can record about the attack!
This data is used for analysis and defence and, if necessary, as evidence.
The basis for data processing is Art. 6 para. 1 lit. c GDPR, the processing is necessary for the fulfilment of a legal obligation to which the data controller is subject.
9. Data acquisition on third party websites
We publish customer and security information, as well as editorial articles on the subject of security in information and communication technology for the customers of these Internet offerings on the following third-party websites. Twitter, Inc. 1355 Market Street, Suite 900, San Francisco, CA 94103, USA Facebook Inc. 1 Hacker Way, Menlo Park, California 94025, USA Mastodon is a microblogging service that is operated remotely by its users.
We have no influence on the personal data processed by these Internet offers! If you use these Internet offers, you must agree to the terms and conditions of the respective provider. We do not process any personal data provided by these system operators.
Last updated: 07.06.2018
This declaration is continuously updated in accordance with the current interpretation of the GDPR.