22VPN Privacy Policy
Summary
- We do not share or sell your personal information. We are strongly committed to protecting user privacy and being as transparent as possible.
- We do not collect logs on VPN servers and we do not know what websites you visit.
- We collect only the information necessary for our products and services to function properly.
- You are not required to share your personal data with us. You can delete your information by deleting your 22VPN account at 22vpn.app or by sending a request to [email protected].
- All purchases are final. We do not offer refunds. See the No Refund Policy section below.
Who we are
22SERVICE LLC-FZ ("We", "Our" or "Us") collects and processes your data in accordance with this Privacy Policy and in compliance with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where applicable, the EU General Data Protection Regulation (GDPR). This Policy provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data. Our general principle is to collect only the information that is necessary to provide you with full functionality of our products and services. We strictly follow the principle of "minimization" when processing your data.
22SERVICE LLC-FZ is a free-zone limited liability company registered in the United Arab Emirates. 22SERVICE LLC-FZ acts as the data controller when processing your data.
If you have any questions about this Privacy Policy or if you want to exercise any of your rights, please contact us at [email protected].
Please read this Privacy Policy thoroughly. If you do not agree with our policies and practices, please do not use our software and services, do not visit our website, and do not provide your information to us.
Compliance with third-party platforms and agreements
22VPN operates in full compliance with:
- Our End User License Agreement (EULA), which governs your use of the 22VPN application and services.
- The EU General Data Protection Regulation (GDPR) where applicable to users located in the European Economic Area.
- The UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).
- The Google Play Developer Program Policies and Google Play Terms of Service for our Android application.
- The Apple Media Services Terms and Conditions, the Apple App Store Review Guidelines, and the Apple Standard EULA for our iOS application.
By installing or using 22VPN through Google Play or the Apple App Store, you also agree to the respective platform's terms in addition to ours. Where there is a conflict between platform terms and ours regarding your purchase from that platform, the platform terms govern that purchase.
What data we process
We process different data depending on the situation. Some data may be treated as personal data ("Personal Data") under the laws of certain territories. "Personal Data" or "personal information" means any information relating to an identified or identifiable natural person, excluding any anonymized and depersonalized data where your identity is absent or has been removed and cannot be recovered.
When you are using our website
When you visit 22vpn.app and its subdomains, we may process limited information necessary for the site to function and for analytics. We use cookies to personalize content (such as setting the default language). None of the information we acquire through the use of cookies is considered Personal Data, as it does not allow us to identify you. You can disable cookies in your browser at any time, but some services may not function properly without them.
Account registration
We process your email address and a hash of the password you provide at registration so that you can retrieve your password if needed.
Sending messages
We may use your email address to make announcements, inform you of updates and new features, provide advice, or communicate with you when reporting errors. You may also consent to receive marketing messages. You can withdraw your consent at any time by unsubscribing through your 22VPN Account or by clicking the "Unsubscribe" link in any newsletter.
Buying a subscription
We process your email address for billing and payment purposes. If you purchase a subscription to 22VPN, we need your contact details to send you information about the purchase. We will also use your email address to create an account that lets you manage your subscription.
Transactions made through our website may be conducted via third-party payment processors. The data processed depends on the payment provider and may include:
- Email address
- Country of residence
- Zip or postal code
- (If you use a bank card) Number, name, expiration date, and the security code associated with the bank card
Purchases made through Google Play or the Apple App Store are processed by Google or Apple respectively, under their own terms and privacy policies. We do not receive your full payment card details from these platforms.
When you are using our software
Sign-in / Account registration. When signing in or registering, you provide your email address and create a password to establish a VPN connection. We process this essential data to provide you with the 22VPN service.
Usage information. When you use our VPN service, we need to make sure that you stay within the agreed-upon limits. Therefore, we collect data on your traffic usage. This is done for two reasons: to prevent misuse of our service and to know when a user's subscription has expired. We store only the number of bytes used by the account; it is not associated with locations. Traffic usage data is stored for 90 days.
We also collect information on the number of instances of our software that have an active VPN connection for both the free and paid versions. We receive this from our VPN servers through which you establish a VPN connection.
Diagnostic / Device information. If you experience problems and give us your consent, we will collect and process diagnostic information for crash reports and information about the device used to run our software in order to help you.
User experience metrics. To analyze and improve functionality, we collect user experience metrics related to interactions with various screens, including:
- Screen name: the name of the screens the user interacts with
- Buttons clicked: actions taken by clicking specific buttons
- Synthetic identifier: a unique identifier used to link multiple events within the same session
All collected data is anonymized and cannot be associated with your 22VPN account under any circumstances. By default this data is not collected. We only gather user experience metrics if you explicitly agree to send them. You may revoke your consent at any time by disabling data collection in the settings of the 22VPN app.
Data we collect on Android (Google Play)
When using 22VPN for Android, we may collect: email address; OAuth provider name (Google/Facebook/Apple, only if used for registration); OS language; app identifier; app version; build identifier; device OS; authorization token; and, if you opt in to crash reporting, device name and model, OS version and kernel build, root status, Android ID, RAM details, screen orientation/resolution/density, and crash-related information (error message, stack trace, last lines of the log file). Crash reports are stored on our servers for 30 days.
Data we collect on iOS (Apple App Store)
When using 22VPN for iOS, we may collect: email address; OAuth provider name (only if used for registration); app identifier; app version; device OS; OS language; Apple AdServices Token (for Apple Search Ads attribution); and, if you opt in to crash reporting, app name/version/build number, library versions, crashed process name, environment type, OS and version, device name/model/ID, and user ID. Crash reports are stored on our servers for 30 days.
Legal bases for processing your Personal Data
- Consent. We process your Personal Data when you have provided consent for specific purposes (e.g., marketing messages, troubleshooting). You can withdraw consent at any time.
- Performance of a contract. We process your Personal Data when necessary to fulfill our contractual obligations to you, including providing the functionality of our software and services.
- Legal obligations. We process your Personal Data where necessary for compliance with our legal obligations, such as to exercise or defend our legal rights, or for taxation purposes.
- Legitimate interest. We process your Personal Data when we pursue our legitimate interests, except where such interests are overridden by your fundamental rights and freedoms.
No Refund Policy
All sales are final. 22SERVICE LLC-FZ does not offer refunds for any subscription purchases, renewals, or in-app purchases made through our website, the Google Play Store, or the Apple App Store.
By purchasing a subscription to 22VPN, you acknowledge and agree that:
- Subscription fees are non-refundable, including for unused portions of any subscription period.
- Cancellation of a subscription will stop future renewals but will not result in a refund of fees already paid.
- If you purchased your subscription through Google Play or the Apple App Store, refund requests are handled exclusively by Google or Apple under their respective policies, and we have no authority to issue refunds on their behalf.
- Where a refund is required by mandatory consumer protection laws applicable to you, we will comply with those laws, but otherwise the no-refund policy applies in full.
Before subscribing, we strongly encourage you to use the free version of 22VPN to ensure the service meets your needs.
Where we process your Personal Data
Your Personal Data is stored on secure servers and may be processed by our employees on a need-to-know basis. If you have questions about which countries your Personal Data may be accessed from, please write to us at [email protected].
For data transfers to other countries, we always implement appropriate safeguards:
- The country or third party is recognized as providing adequate protection.
- A valid transfer mechanism is used, such as Standard Contractual Clauses, with supplementary measures where necessary.
- The transfer has your explicit consent.
- The transfer is necessary for the performance of a contract with you.
Retaining your data
We retain Personal Data for as long as necessary to provide you with our products and services, or until you withdraw your consent. Crash reports are retained for 30 days. Traffic usage data is retained for 90 days.
Your rights
Depending on your location, you may have the following rights regarding your Personal Data:
- Right of access: Obtain all Personal Data we store about you.
- Right to erasure (right to be forgotten): Delete your Personal Data via your 22VPN Account or by emailing [email protected].
- Right to rectification: Correct any incomplete or inaccurate Personal Data.
- Right to restriction: Restrict the processing of your Personal Data.
- Right to object: Object to the processing of your Personal Data.
- Right to data portability: Receive your Personal Data in a structured, commonly used and machine-readable format.
- Right not to be subject to automated decision-making, including profiling.
- Right to withdraw consent where data processing is based on consent.
- Right to lodge a complaint with the competent data protection authority in your jurisdiction.
To exercise any of these rights, contact us at [email protected]. We may ask you to confirm your identity and will respond within the time frame required by applicable law.
Safeguarding measures
We make every reasonable effort to protect your Personal Data from unauthorized access, alteration, disclosure or destruction:
- System access controls: Authentication via passwords and/or two-factor authentication, documented authorization processes, change management, and access logging.
- Data access controls: Restricted database access and role-based application permissions.
- Secure storage: Personal information is stored in secure data centers with appropriate physical and logical protections.
- Transmission controls: Encrypted transmission of Personal Data.
- Input controls: Logging of who entered, modified, or removed Personal Data.
- Data backup: Regular encrypted backups of our databases.
- Logical separation: Personal Data collected for different purposes is logically segregated.
Consequences of not providing your Personal Data
You are not obligated to provide your Personal Data to us. However, as this information is required for us to provide our services or respond to your requests, we will not be able to offer our services without it.
Age limitations
To the extent not prohibited by applicable law, we do not allow the use of our Services, Products, and Website by persons under the age of 18. If you learn that someone under 18 has unlawfully provided us with Personal Data, please contact us at [email protected] and we will take steps to delete that information.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time and inform you of any important changes. Laws, regulations and industry standards evolve, which may require these changes, or we may update our business practices. We will post any changes on this page and encourage you to review the Privacy Policy periodically to stay informed.
Contact
22SERVICE LLC-FZ
United Arab Emirates
Email: [email protected]
Website: https://22vpn.app
Together with the Terms of Service and the No-Log Policy, this document forms the agreement between you and 22SERVICE LLC-FZ.