Privacy Statement

Your privacy is important to Vedivi. Therefore, Vedivi is committed to respecting Your privacy and the confidentiality of Your personal data, traffic data and communications content.

This Privacy Statement is designed to assist You in understanding how Vedivi uses and safeguards the information You provide in using Vedivi's virtual private network software and/or Pass Service.

Vedivi collects and processes, or has third party service providers who collect and process on Vedivi's behalf, personal data relating to You, as permitted to

1. provide the virtual private network Service, in particular to convey data You exchange by means of the WallCooler Software and/or the Pass Service,
2. invoice to You Your use of the Pass Service and
3. carry out Vedivi marketing activities.

In this Privacy Statement the following capitalized definitions are being used, singular as well as plural.

• Communications Content: any information that is exchanged by users of WallCooler Software and/or Pass Service.
• Feedback Information: any information that is reported to Vedivi by filling in the feedback forms on the Website.
• Passive Information: Information that is necessary in order to provide You with the desired functionality of the WallCooler Software, such as a session ID token, source and destination addressing information, computer name, and the version of the software You are using.
• Personal Data: any information that Vedivi possesses relating to an identified or identifiable user of WallCooler Software and/or Pass Service.
• Register Information: any information provided when voluntarily registering at the Website, including, but not limited to, e-mail and password.
• Vedivi: means under this Privacy Statement the Vedivi Limited, a company incorporated under the laws of the United Kingdom, having its registered office at 36 Lennox Gardens, London SW1X 0DH, United Kingdom.
• WallCooler Software: Virtual private network software that allows You to exchange data with any other Vedivi user through network communication and/or other forms of communication, through the Internet.
• Subscriber Information: Information that is necessary in order to verify Your identity and to provide Pass Service, such as Your name, billing information and e-mail address on the Website.
• Traffic Data: any data processed for the purpose of the conveyance of exchanging data or the billing thereof, including, but not limited to, the name of the computers, IP addresses of the computers, the duration of the communication, the amount of data exchanged between the parties.
• User Profile: any information about the user, filled in by the user on the Website.
• Pass Service: means the payable services provided by Vedivi and/or Vedivi's partners, including but not limited to, the extra speed (bandwidth) and data transfer service and other services which may be extended or changed from time to time.
• Website: the website located at www.vedivi.com.
• You: You, the user of the WallCooler Software and the Pass Service, also used in the form "Your" where applicable.

Vedivi is a limited company established under the laws of the United Kingdom.

Through the Website, Vedivi Limited offers you the WallCooler Software and Pass Service, which may be extended or changed from time to time.

In order to provide the WallCooler Software, Vedivi gathers and processes the following information:

• Register Information
• User Profile
• Feedback Information
• Passive Information
• E-mail addresses

In order to provide You with Pass Service, Vedivi shall, in addition to the above mentioned information, collect and process the following information:

• Subscriber Information
• Traffic Data

Our primary purpose in collecting information is to provide You with a safe, smooth, efficient, and customized experience. We may use the information defined in this Privacy Statement to:

• provide the services and customer support You request;
• resolve disputes, collect fees, and troubleshoot problems;
• enforce our Terms of Service;
• customize, measure, and improve WallCooler Software, Pass Service and Website content and layout;
• inform You about targeted marketing, service updates, and promotional offers unless You opt out;
• compare information for accuracy, and verify Your identity;
• provide other services for You as described when we collect the information.

Additionally we may use Your information as described below.

• Register Information: You do not need to register to use the WallCooler Software, but Register Information may be needed if You want to use particular services of Vedivi.
• User Profile: Vedivi stores the User Profile centrally on a server. You can access Your User Profile from the “Home” tab after you login to your account on the website in order to view, correct, complete or remove information.
• Feedback Information: Any and all information which is voluntarily submitted in feedback forms on the Website, is used for the purposes of reviewing this feedback and improving the WallCooler Software, Pass Service and Website. Vedivi reserves the right to utilize anonymous information for marketing purposes, for instance by displaying selected comments on the Website or in other communications. Further, Vedivi may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time in any obligation to provide any of such data. Vedivi will never use any personally identifiable (feedback) information without Your explicit permission thereto.
• Passive Information: Passive Information is automatically generated and is stored centrally. Vedivi will only use this Passive Information, to provide You with better service, to show You your activity or for statistical information.
• E-mail addresses: Vedivi respects the privacy of personal e-mail accounts and stores Your e-mail addresses just as securely as other Personal Data. Vedivi will not send You unwanted e-mail messages or junk mail, and Your details will not be passed to third parties for their marketing purposes. However, Vedivi will use e-mail to send You messages about faults and service issues. Vedivi may also use e-mail to keep You up to date with news about the Wallcooler Software and Pass services. If You do not want to be kept informed in this way by e-mail, please contact Vedivi at support@vedivi.com. Further, Vedivi reserves the right to use e-mail to notify You of any eventual claims related to Your use of WallCooler Software and/or Pass services, including without limitation claims of violation of third party rights.
• Subscriber Information: Vedivi asks for Subscriber Information in order to verify Your identity and to provide Pass Service. We use third party banking organizations and other providers of payment services to bill You for Pass Service and we will, therefore, provide this billing provider with the necessary billing data. Vedivi does not collect or retain any information related to Your payment card details. When You decide to purchase Pass services, at the time of collecting such details, You will be trasnfered to our secure third party banking organizations and other providers of payment services to fill in and process your payment data. Vedivi will keep a reference of this payment provided by such third parties for refund and audit purpose. No credit card or other sensitive card details are stored, read or accessed by Vedivi. Please note that Your billing data is sensitive information, which can be used to find out information about Your use of Pass Service. Please be sure to keep this information safe and do not share it with others.
• Traffic Data: In order to exchange data using the WallCooler software, display your activity and statistics in your account and to bill the Pass service, Vedivi collects Traffic Data. However, Vedivi is unable to read or understand any such data, apart from the size and time of exchanging this data, because all traffic is encrypted (SSL 128-bit and Your own private key) by the WallCooler software before it sends the data over the Internet to the Vedivi servers and only the receiving WallCooler Software is able to decypher and read such information. Vedivi will not store encrypted Traffic Data.

Except as provided below, Vedivi shall not sell, rent, trade or otherwise transfer any Personal and/or Traffic Data or Communications Content to any third party, unless it is obliged to do so under applicable laws or by order of the competent authorities.

Vedivi may share your information with its Affiliates (as defined in the End User License Agreement).

In order to provide You with Pass Services or other services You have requested, Vedivi may sometimes, if necessary, share Your Personal data with the third party banking organization or other providers of payment services. Vedivi will always require these third parties to take appropriate organizational and technical measures to protect Your Personal Data and to observe the relevant legislation.

Please be informed that, notwithstanding the abovementioned, in the event of a designated competent authority requesting Vedivi or Vedivi’s local partner responsible towards such authority, to retain and provide Personal and/or Traffic Data statistics, Vedivi and/or its partners will provide all necessary assistance and information to fulfill this request.

Information collected on the Website or otherwise may be stored and processed in any country in which Vedivi and its affiliates maintain facilities, including outside of the EU. In this regard, or for purposes of sharing or disclosing data in accordance with this article, Vedivi reserves the right to transfer information outside of Your country.By using WallCooler Software or Pass Service You consent to any such transfer of information outside of Your country.

As Vedivi continues to develop its business, Vedivi might sell or buy subsidiaries or business units. In such transactions as well as in the event Vedivi or substantially all of its assets are acquired by a third party, personal information of Vedivi users will generally be one of the transferred business assets. We reserve the right to include Your personal information, collected as an asset, in any such transfer to a third party.

Cookies are pieces of information that Vedivi will transfer to Your computer’s hard drive through Your browser to enable Vedivi´s systems to recognize Your browser.Cookies also enable Vedivi to gain information about the use of its Website and to enhance the Website accordingly to the preferences of the users.

The Help option on the toolbar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether. Vedivi’s cookies do not contain any identifying information.

Please bear in mind that some personalized services may not be available if You choose to disable cookies.

The Website may contain links that will let You leave the Website and access another website.

Linked websites are not under the control of Vedivi and it is possible that these websites have a different privacy policy. The Privacy Statement applies solely to personal information that is acquired on the Website, so Vedivi urges You to be careful when You enter any personal information online.

Vedivi accepts no responsibility or liability for these other websites.

Vedivi shall take appropriate organizational and technical measures to protect the Personal Data and Traffic Data statistics provided to it or collected by it, and shall not retain it any longer than permitted in order to perform its services or as required under relevant legislation.

Your Personal and Traffic Data statistics can only be accessed by authorized employees of Vedivi who need to have access to these data in order to be able to fulfill their given duties.

Vedivi shall take appropriate technical measures to protect the confidentiality of the Communications Content via its Vedivi Software and Pass Services, with due observance of the applicable obligations and exceptions under the relevant legislation.

Vedivi reserves the right to modify the provisions of this Privacy Statement if deemed necessary.

We will inform You of these changes by publishing the revised Privacy Statement at www.vedivi.com/company/legal/privacyPolicy.

The revised Privacy Statement shall become effective within thirty (30) days of such publishing, unless You expressly accept the revised statement earlier by clicking on the I Agree button.

You agree that the express acceptance by You, or Your continued use of the WallCooler Software or Pass Service after the notice period of thirty (30) days, shall constitute Your acceptance of the Privacy Statement.

If You would like to exercise your right to view, correct, complete or remove Your Personal Data, please contact Vedivi at support@vedivi.com.

Within a reasonable period of time and upon verification of Your identity, Vedivi will fulfill Your request, provided Vedivi will not act contrary to applicable legislation by fulfilling Your request.

Vedivi will retain Your information for as long as is necessary to:

1. perform the Free virtual private network or Pass Service;
2. invoice to You Your use of the Pass Service and to maintain records until invoicing for the Pass Service cannot be lawfully challenged and legal proceedings may no longer be pursued;
3. carry out Vedivi marketing activities;
4. comply with applicable legislation, regulatory requests and relevant orders from competent courts;
5. enforce our Terms of Service; or
6. fulfill any of the other purposes detailed in this Privacy Statement.