Privacy Policy

ComlinkVPN is a leading provider of digital security products for consumers. This Privacy Policy describes how we process and handle data provided to ComlinkVPN in connection with your use of our products, services, apps, and websites that link to this policy (we refer to these collectively as our “services”).

Information security and privacy are at the heart of what ComlinkVPN values and promotes as a company. As such, we think it’s important to be transparent about how we handle your information. That level of transparency also makes for a lengthy document, but we’ve tried to make it more readable by organizing it into a logical structure and using plain language.

ComlinkVPN offers a variety of services, and this policy describes our comprehensive approach to ensuring privacy considerations across all our services. We have some unique approaches to managing data for certain of our products and services. Please refer to “Product Specific Privacy Notices” below for more details.

This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person.

1. Collection and use of user information

The information we collect and how we collect it is as follows:

1.1. Information you provide to us

1.1.1. The information you fill in, submit or access when you register/complete your information may include your real name, email address, mobile phone number, password, relevant data and other similar personal data.

1.2. Information collected during your use of App services

1.3. Relevant information provided when you contact our customer service team (including but not limited to your personal data), consultation records, and questionnaire response information sent to us when you participate in the survey.

1.4. When using the services provided by the App, the information you publish and publish.

1.5. For the purpose of providing services to you, if you voluntarily fill in or provide registration or subscription required by us, which may include real name, certificate type and certificate number, email address, telephone number and other similar personal data, then It means that you have understood and accepted the collection, protection and use of your personal data by APP in accordance with this Privacy Policy.

1.6. How we use information

We use the collected information to provide you with services and improve service quality. In order to achieve this purpose, we will use your information for the following purposes:

1.6.1. Accept verification codes when registering, logging in, binding accounts, and retrieving passwords

1.6.2. Other purposes with your permission.

In order to enable you to use the complete App functions and improve your experience, your personal information may be collected and used in our following extended functions. If you do not provide such personal information, you can still use it, but you may not be able to use some extended functions. These extensions include:

The above-mentioned extended functions may require you to enable your external storage in your device to realize the collection and use of the information involved in these functions. Please note that if you enable these permissions, you authorize us to collect and use these personal information to achieve the above functions. If you close the permissions, you cancel these authorizations, and we will no longer continue to collect and use your personal information. information, and cannot provide you with the above-mentioned functions corresponding to these authorizations. Your decision to close the permission will not affect the previous processing of personal information based on your authorization. In addition, we may also require you to enable other access permissions of the device in related business functions. The detailed permissions and purpose of use are as follows:

  • (1) Access to the network permission: to achieve application networking
  • (2) Obtain WiFi status permission: monitor network changes and prompt the user for the current network environment
  • (3) Obtain network status authority: monitor network changes and prompt users for the current network environment
  • (4) Mobile phones below Android 10 obtain IMEI permission: Android 10 and below are not necessary for the purpose of counting the conversion rate of advertisements
  • (5) Change WiFi status permission: allow apps to change WiFi status

2. Sharing, transfer and public disclosure of user information

2.1. Sharing

We are obliged to keep your information confidential, and will not sell or rent any of your information to third parties for their marketing or illegal purposes. We will only share your information with third parties under the following circumstances:

2.1.1. Obtain your express consent or authorization in advance.

2.1.2. Disclose to third parties or administrative agencies, judicial agencies, law enforcement agencies or regulatory agencies in accordance with the provisions of laws and regulations, litigation, arbitration settlement needs, or at the request of administrative or judicial agencies.

2.1.3. If you violate applicable laws, regulations, service agreements or related policies, you need to disclose to third parties.

2.1.4. To safeguard the legitimate rights and interests of the App and its affiliates or users.

2.1.5. Other disclosures deemed necessary in accordance with laws, regulations or relevant policies.

2.2. Transfer

We will not transfer your user information to any company, organization or individual.

3. Who Do We Share Your Information With and Why?

In some situations, ComlinkVPN may share your information with third parties who may collect, store, use, process and transfer the data for ComlinkVPN. ComlinkVPN employs oversight processes and controls to the secure sharing of data with only trusted parties.

Neither ComlinkVPN, nor any of the companies that comprise ComlinkVPN, sell your personal data (except if you utilize our free products).

3.1. In General

We may disclose your information in the following circumstances:

  • In accordance with your instructions or consent. For example, some services may allow you to register an account using a third-party account (such as a Google or Microsoft account). If you choose to do so, we will share information with the third-party account provider.
  • To your business organization (for our business services). If a business customer is providing you with access to our services through a business account, others in that organization may be able to see and manage your account and the information associated with it (such as an administrator).
  • For collaborating with others. Some services may provide ways for different users to interact or collaborate with each other. Your information will be shared in connection with those activities if you choose to engage in them.
  • With our partners. We may provide your personal data to partners to confirm your eligibility for joint or co-branded offers or to communicate and administer such offers (e.g. verify eligibility, assess effectiveness of joint offer, etc.). Our partners are not allowed to use any data including personal data that they receive from us for any purpose except for communicating, evaluating, improving, and administering the offer in question. This will not affect the partner’s ability to use personal data that it may already have obtained from you or other sources. If you do not wish to receive promotional emails from our partners, you can unsubscribe directly using the unsubscribe link or tool provided in the partner’s email or other communication to you.
  • Third-party service providers. With the exception of any data collected through your use of our virtual private network where our VPN Product Privacy Notice applies, we may disclose the information we collect to service providers to help us provide some aspects of our services, we work with trusted third parties and partners . In cases where we may share your personal data, we enter into appropriate confidentiality and data processing agreements with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with. Examples of activities that third parties help us with include:
    • processing customer payments
    • providing analytics about our services to help us understand how the services are being used
    • providing sales and customer support
    • maintaining the infrastructure required to provide our services
    • delivering our marketing and advertising content
  • For security research purposes. A sanitized subset of our threat intelligence data may be shared with selected reputable members of the cybersecurity industry for the purpose of security threat research and facilitating community efforts to improve online security.
  • In connection with a business transaction. If a substantial corporate transaction occurs, for example changes to ownership or control of all or part of our services, assets, or business, sale of a website, initial public offering, or an investment entity is conducting due diligence in connection with an acquisition or investment, then we may share the personal data we collect in connection with that substantial corporate transaction.
  • Aggregated or de-identified data. We may aggregate and de-identify any data we collect and use and share such data so that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.
  • To comply with legal process and the law. If you use our VPN product, we protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. Subject to the foregoing, we may share your information if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose ComlinkVPN, you, or any of our other users to legal liability. If we share your information for these purposes, we limit the information shared to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
  • To enforce our rights and prevent fraud and abuse. We may share limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against ComlinkVPN. We may also share your information in order to protect against fraud and abuse against ComlinkVPN, our affiliates, users and others.

3.2. Products Provided Free of Charge

ComlinkVPN offers some products for free, with no charge to you at all. For these products, we do help cover the costs of providing these services by displaying ads in certain regions for which we receive compensation from advertisers. We do not display third party ads in our paid products.

Displaying Ads. With respect to our free mobile apps and other free products, we may serve ads to users in certain regions. Although the money we make from displaying these ads offsets only part of the costs of making these apps and services available for free, we provide free apps because we believe it’s important that everyone has the opportunity, regardless of their situation, to have secure and private access to the internet.

The ads we display in our services are supplied either by advertisers or affiliate networks we have relationships with, or by Google, or other third-party advertising networks (“third-party ad networks”). To display these ads in our apps, we may integrate into them a software development kit (SDK), which consists of software code provided by a third party, such as an ad network.

We do not provide third-party ad networks with any personal data about you, except for an approximate city-level latitude and longitude which lets them show ads which are more relevant for your approximate geographic location. However, third-party ad networks may collect information through their SDKs, such as your mobile advertising identifier, IP address, and device information, for the purpose of serving you with “personalized” ads (ads that they think are more relevant to you) and measuring your response to those ads. If you are using a VPN connection, your IP address is hidden from ad networks and replaced with the IP address of our VPN servers. Because we do not provide ad networks with personal data about you (apart from city-level location), third-party ad networks personalize ads based on information that they collect from you and that they already have about you - not based on information we share with them.

Google collects this information according to the Google advertising privacy notice. Where an AdChoices logo appears on an ad, you can click it to learn more about the ad network that provided the ad, its privacy policy, and your choices regarding opting out from any personalized advertising, as explained further below in “Tracking Technologies & Cookies.” If you opt out from personalized advertising, you may still see non-personalized ads.

While we request you not to use ad blockers to prevent the display of ads because that is how we support our free services, our services are able to continue functioning if you do use ad blockers.

4. Tracking Technologies & Cookies

About Tracking Technologies

ComlinkVPN collects certain information by automated means when you interact with our Services. Like many companies, ComlinkVPN uses various technologies including “cookies” and related technologies such as pixel tags on our Services to help us collect information, primarily on our websites and in our marketing emails. Our Service Providers (such as analytics providers) may also place cookies and similar technologies on the Services. For convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals.

Tracking technologies include:

  • Cookies: Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for. Please see our Cookie Policy for more details.
  • Pixel Tags / Page Tags / Web Beacons / Tracking Links: These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link.
  • Google Analytics: We use Google Analytics to help us understand how users use our services. Google makes available a Google Analytics Opt Out Browser Add-On if you do not want to participate in Google Analytics.

When you visit Our Site, ComlinkVPN may view and/or store the IP address of the device you are using. ComlinkVPN uses this information to determine the general physical location of the device and understand from what regions of the world Our Site’s visitors come from. ComlinkVPN also may use this information to enhance the Site.

5. Security

Securing personal data is an important aspect of protecting privacy. ComlinkVPN employs a range of administrative, organizational, technical, and physical safeguards designed to protect your data against unauthorized access, loss, or modification. We endeavor to use reasonably available state-of-the-art network and information security standards, protocols and technologies, including encryption, intrusion detection and data loss prevention, and we monitor our systems to ensure that they comply with our security policies.

We implement physical, technical and organizational safeguards to protect your personal data in our custody, both at rest and in transit, and should these measures fail to prevent a data breach, we will promptly take the necessary remedial measures, and we will provide notices as required by applicable law.

If you have any questions about the security of your personal data or the security of our products, or wish to report a potential security issue, please contact [email protected]. When reporting a potential security issue, please describe the matter in as much detail as possible and include any information that might be helpful.

6.Data Retention

ComlinkVPN generally retains your personal data for as long as is needed to provide the services to you, or for as long as you have an account with us. We may also retain personal data if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss.

7. Privacy Policy Updates

We may revise this policy from time to time. Review it occasionally so that you keep up-to-date on our most current practices. We will put the ‘Last Updated’ date at the top of each policy. If you disagree with such an update to this policy, you may cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued use of our services will be subject to the updated Privacy Policy.

8.Contact Us

We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or complaints about our privacy practices, you can contact us at [email protected] or at the following addresses