We are Home VPN Ltd (referred to as Home VPN, we, us, and our in this Privacy Policy), a company incorporated in England and Wales with company registration number 14494236 and whose registered office address is 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE.
The information set out in this Privacy Policy is provided to individuals whose personal data we collect (you or your) as data controller in compliance with our obligations under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
This Privacy Policy applies to your use of our Services. By the Services, we mean any of our websites, applications, and any other products, content, or services that link to this policy. This Privacy Policy is an integral part of the Terms and Conditions of Use (Terms of Use).
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you (such as the use of your account within our Services), so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
We are the data controller in relation to the processing of the personal data that you provide to us. Our contact details are as follows:
You may provide your personal data to us when you choose to use our Services. Because we change our offerings and features from time to time, the options you have to provide us with information also may change.
Generally, the information we hold about you comes from the way you engage with us and our Services, for example by doing any of the following:
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The specific types of information you may be able to provide us will often vary depending on which of our Services you are using and how you interact with us.
The types of personal data that we may collect, use, store, and transfer about you are as follows:
The types of data listed above do not include information about your browsing and internet activity when connected to the VPN. As outlined in the Terms of Use, we do not collect, store, or disclose data regarding your online activities.
We may collect information about you from third-party service providers or information that is publicly available. This may include information such as your age, identity, and any other publicly available information.
We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we would then treat the combined data as personal data which will be used in accordance with this Privacy Policy.
What do we use your information for?
| Purpose | Type of Data | Lawful Basis for Processing (Including Basis of Legitimate Interests) |
|---|---|---|
| To register you with us. | Contact data | Necessary for our legitimate interests (to keep our records updated) |
| For administering your account. | Contact data, Account profile data | Necessary for our legitimate interests (such as creating and administrating your account); Performance of a contract with you |
| Sending marketing communications to you. | Contact data, Marketing and communications data | Consent; Necessary for our legitimate interests (to provide you with information related to services or similar services that you already receive) |
| Sending communications to you about new features of our Services. | Contact data, Account profile data | Performance of a contract with you; Necessary for our legitimate interests (to give you the best user experience and present you with relevant similar activities) |
| To administer and protect our business and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). | Contact data, Technical data, Location data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and fraud prevention) |
| To prevent connections between certain countries (e.g., Ukraine and Russia) and users connecting to countries in which they are located (e.g., connecting to the UK from the UK). | Location data | Necessary for our legitimate interests (to prevent misuse and/or illegal use of the Services, fraud prevention) |
| To use data analytics to improve our Services, marketing, customer relationships, and experiences. | Technical data | Necessary for our legitimate interests (to define types of customers for our services, keep our website updated and relevant, develop our business, and inform our marketing strategy) |
| To manage our relationship with you including informing you about changes to our Terms of Use or Privacy Policy and ensuring you have access to our Services. | Contact data, Other voluntary information | Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated) |
We will use your personal data only 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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at hello@homevpn.org.
If we need to use your personal data for an unrelated purpose, we will either obtain your explicit consent or we will notify you and set out the legal basis which allows us to do so.
Personal data we are holding about you may be shared with and processed by:
We include links within our website to third-party social media providers such as Instagram, but we will not share your information with such providers without your consent.
In order for you to be able to use our Services, we may need to transfer personal data relating to you outside the United Kingdom (UK).
We will not transfer personal data relating to you to a country outside the UK unless one of the following scenarios under UK GDPR applies:
We may from time to time make chat rooms, message boards, news groups, and/or other public forums available to users of our Services. Any information that is disclosed in these areas becomes public information, and you should exercise caution when using these and avoid posting any personal data.
Protecting the safety of children when they use our Services is important to us.
We may ask you to provide age-related information in order to help us comply with relevant laws and guidance, such as the Age Appropriate Design Code. For example, we may request your date of birth to determine whether the Age Appropriate Design Code requires us to obtain verifiable consent from your parent or guardian before allowing you to access our Services.
If a user indicates that they are a minor, we will require consent from their parent or guardian before allowing access to the relevant Services. This process is designed to notify parents or guardians that their child has requested access to our Services, inform them about our privacy practices, offer them the opportunity to approve our collection and use of their child’s information as described in this Privacy Policy, and describe the controls that we make available to them.
Once a parent or guardian provides their consent, we will give them an opportunity to review and change important account settings that control how their child can interact with our Services. Parents or guardians are also generally free to change or revoke the choices they have previously made and will be able to review the personal data associated with their child’s account or request that we delete it from our systems. To submit these requests or ask us any other questions you may have about how we handle your child’s personal data, please contact us at hello@homevpn.org.
Authorised child accounts are otherwise treated much like other accounts that use our Services. They may generally access communications and social features (like chat and friends lists) and freely interact with most of our Services.
Unless we are required or permitted by law to hold on to your data for a specific retention period, we will hold your personal data only for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. In particular:
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorized 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, regulatory, tax, accounting, or other requirements.
Where we no longer need your personal data, we will dispose of it in a secure manner.
In some circumstances, you are entitled to ask us to delete your personal data. See your legal rights at paragraph 12 below for further information.
You have certain rights under existing data protection laws, including the right (following a written request) to access a copy of your personal data that we are processing. In accordance with the UK GDPR, you will have the following rights:
In certain circumstances, you will also have the following rights:
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.
We try to respond to all legitimate requests within one month. Occasionally, it could 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.
You have the right to unsubscribe from our marketing communications at any time by following the link in the footer of the last email you received from us (“Unsubscribe”) or by sending your request with detailed instructions to us (see contact details above in the “Data Controller details” section).
Please note that if you withdraw your consent to the use of your personal data for purposes set out in our Privacy Policy, we may not be able to carry out our contractual obligations to you or provide you with access to all or certain parts of our Services.
If you consider our use of your personal data to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk.
We do not make decisions based solely on automated data processing, including profiling.
We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction, or damage. For example:
However, while we will do our best to protect your personal data, we cannot guarantee the security of your information which is transmitted via the internet or a similar connection. It is important that all details of any username, password, and/or other identification information created to access our Services are kept confidential by you and should not be disclosed to or shared with anyone.
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.
Our Services do not use “cookies” explicitly. However, the app may use third-party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or may not function properly.
The Services may contain links to external websites, mobile software applications, products, or services that are not owned or controlled by Home VPN and may be subject to specific terms and conditions. Home VPN is not responsible for the privacy practices or the content of such external websites. We strongly recommend that you read the terms and conditions and privacy policies of each third-party service provider you engage with in connection with the Services.
Links to the privacy policies of third-party service providers used by Home VPN services are listed below:
We may amend this Privacy Policy from time to time, for example, to keep it up to date, to implement minor technical adjustments and improvements, or to comply with legal requirements. We will always update this Privacy Policy on our website, so please try to read it when you visit the website or before, after or while using the Service / Application