Privacy Policy

What personal data do we process?

We believe in data minimisation and only collect minimal personal data when you access or use our Services. We don’t collect any information that could lead us to know what you’re up to online. Depending on how you use our Services, we collect the following personal data from you:

1.1. Website visitors’ data

As with most websites on the internet, when you visit our Website, we may collect access logs (such as IP address, browser type, and operating system) to operate our Services and ensure their secure, reliable, and robust performance. This information is also essential for fighting against DDoS attacks, scanning, and similar hacking attempts.

Legal basis

Our legal basis for processing the Website visitors’ data is our or a third party’s legitimate interest to secure and improve the performance of our Website. Please note that although we collect and process our Website visitors’ data, we do not monitor our users’ online activities while they use the Angel VPN applications.

1.2. Account registration data

When you sign-up for our Service, we collect the following personal data from you:

• Name;

• Email address; and

• Payment data

We process your email address to create your Angel VPN user account, enable you to securely sign in to your account, assist you in recovering your lost account password, and enable you to use the Service.

We collect your name and payment data to process your subscription payment and handle refund requests. Please note that your payment data, as processed by our payment partners and us includes the payment card owner’s full name, billing address, date of subscription, IP address and country of purchase. We also process some of such billing information ourselves (date of purchase, credit card owner’s full name, part of your credit card number, and its expiration date) in cases of recurring payments or when you provide your payment details directly to us.

The data relating to the country of purchase is used to calculate applicable taxes such as Value Added Tax/Sales Tax and for collection and remittance of these taxes to the relevant authorities.

Our payment partners may also process the above-mentioned personal data to identify and prevent payment fraud. A payment transaction that is considered high-risk may be rejected by us.

Participation in referral programs maintained by us requires referrers to submit personal information (full name, email address, phone number, relationship with the referred party) about themselves and a referred party so that Nord could reach out to the referred party; contact referrers with regards to their participation in referral programs and/or provision of rewards. It is the referrer’s responsibility to abide by applicable privacy laws when disclosing third parties’ personal data to us, including informing third parties that they are providing referred parties’ personal data to Angel VPN and how it will be used and processed. Referred parties may unsubscribe from any future communication at any time. If you believe that one of your contacts has provided us with your personal data and you would like it to be removed from our database, please contact us.

Legal basis

Our legal basis for processing the account registration data includes the performance of our contract to provide access to our Service and to process the subscription payment for the Services.

To the extent we are required to calculate, collect/remit any taxes and maintain records for demonstrating our compliance with tax laws, we rely upon the fulfilment of our legal obligation as the legal basis of such processing.

1.3. Performance and Support Data

We also process data to provide you with support and to monitor/improve our Service. The data we process includes the location of the VPN server you connect to, the day you connect with our Services, the duration of your connection, diagnostic information and crash reports on our applications, your ISP/City, the total bandwidth use and consumption, and your email address.

Please note that we do not track or store data relating to the server you connect to, the IP address assigned to those servers, your IP address, your exact location, or the time when you connected. We track each user’s total bandwidth consumption only to ensure that all our users receive the highest speed and best experience of our Service. We do NOT track or store bandwidth for every single session. We process diagnostics information and crash reports to improve our understanding of our Service and its usage frequency. We gather aggregated usage and performance data to ensure that our Service is working properly. Notwithstanding anything to the foregoing, we do NOT store any logs that can identify or help in monitoring your activity.

NONE of the following records are stored by Angel VPN (Browsing activity, Identifiable connection logs, Records of IPs assigned, A customer’s original IP, Connection timestamps, Browsing history, Sites visited, Outgoing traffic, Content or data accessed, DNS queries generated by the user.

Legal basis

Our legal basis for processing the above Performance and Support data is our or a third party’s legitimate interest in providing support services to our users and improving the performance of our Service.

1.4. Communication data

We process your personal data when we communicate with you through email, live chat or when we send push notifications to you.

• 1.4.1. Email

• When you contact us via email, we will process your email address and the content of your email message to respond to your enquiry.

• If you are an Angel VPN account holder, we will also process your email address and name to send you relevant information on any system-related updates and other important notices about our Services.

• If you subscribe to receive marketing communication from us, we will process your name and email address to send you promotional offers, surveys and other direct marketing material. Please note that you can opt out of receiving marketing communication anytime by clicking the unsubscribe button in the marketing emails.
  Please note that we may make use of third-party tools that assist us with optimising our email campaigns. These tools may track how you interact with our emails, your device’s operating system, and your country for language selection.

• 1.4.2. Live Chat

  If you contact us through our live chat, we will process your IP address, the operating system and the browser on your device. We use this information to determine your country, prevent abuse, determine if you are connected to our servers and provide support as needed.

• 1.4.3. Push Notifications

  We may send push notifications to your device. Please note that some operating systems automatically permit push notifications; however, if you wish to disable push notifications, you can easily deactivate them by changing your device settings.

Legal basis

When you send us an email enquiry or when we send you system-related information, we rely on our legitimate interest as the legal basis for processing your personal data. When you opt-in to receive marketing communication from us or when we send push notifications to you, we rely on your consent as the legal basis for processing.

• 1.5. Social media data

  If you interact with us through our social media pages, such as our “Facebook”, “Instagram”, “Twitter”, “LinkedIn”, ”YouTube”, and “Reddit” accounts, we may collect and process your personal data, such as your full name, publicly available information on your social profile, images, comments or other information that you voluntarily submit.

Legal basis

Your consent is our legal basis for processing your personal data when you interact with our social accounts or content.

• 1.6. Technical data

  We automatically collect some technical data when our users use our Services, such as whether a user connected with our Service in the last 30 days and server net usage data. We use the connectivity data to prevent abuse of our Service and challenge any unfair chargebacks. We use the server net usage data to recommend the most suitable server to our users. This technical data does not contain any personal data.

• 1.7. Cookies

  Cookies, pixels, and other similar technologies are usually small text or image files that are placed on your device when you visit our Websites. Some cookies are essential for our Websites to operate smoothly; others are used to improve Websites’ functionality, analyse aggregated usage statistics to improve Websites’ performance, and for advertising. We also use affiliate cookies to identify the customers referred to our Websites by our partners so that we can grant the referrers their commission.
  
  You can control the use of cookies at the individual browser level on your device. To disable cookies, follow your browser instructions on how to block or clear or decline all third-party cookies. Please visit our Cookie Policy to learn more about what cookies we use and how we use them.

Retention of personal data

As a no-log service, we only process limited personal data. We do not retain your personal data for longer than required for the initial purpose for which we collected it, and in no event do we retain it after we cease to have a legal basis for processing.

Personal data that is processed for the provision of our Services will be retained for the entire duration that you are subscribed to our Services. Upon expiration or termination of your account and/or Subscription, Angel VPN will immediately cease processing information that’s associated with you. However, please note that there might be cases when we retain information associated with you after the expiration or termination of your account and/or subscription: in order to fulfil its obligations as required by applicable laws, regulations, court orders, subpoenas, or other legal processes for archival purposes.

Once your personal information is no longer needed to support our ongoing legitimate business, we will delete and/or anonymise such information. If this is not possible, we will store your personal information in a secure and isolated environment so that processing it is no longer possible. And when a deletion process is possible, the personal information will be deleted.

Angel VPN will use your email for marketing communication even after the end of your subscription. Please note that you can opt out of receiving marketing communication anytime by clicking the “unsubscribe” button in the marketing emails or contacting us at [email protected].

Personal data that is processed to engage with you through our social media accounts will be retained as long as you are an account holder of such a social network.

If you do not agree with the processing of your personal data by Angel VPN, please do not use our Services and Websites. You can request us to discontinue processing your personal data, in which case your data will be processed only as much as it is necessary to effect the discontinuation of your use of the Services (e.g., final settlement or deleting all personal data based on your email address), or finalising other Angel VPN’s legal relationship with you (e.g., record keeping, accounting, processing refunds). Please note that our third-party service providers or we may be obliged to retain your certain personal data as required by law.

If you are in the UK or EEA and you exercise your right to request the deletion of your personal data, we will delete such personal data in accordance with our obligations under the GDPR except in instances where we have another legal basis to retain your personal data such as:

• If you are party to any unresolved dispute with the Company, the Company may retain all necessary personal data until such dispute is resolved;

• For our compliance with applicable law; and/orEmail address; and

• For our legitimate business interests, including preventing fraud or protecting our users.

If we cease to have a legal basis for processing your personal data, we will either delete or irreversibly anonymise your personal data so it cannot be linked back to you.

Data Subject Rights

If you are in the United Kingdom or the EEA, you have the following rights as a data subject:

3.1. Right to access your personal data that we process

You have the right to request access to your personal data or a copy of your personal data that we have by contacting us at [email protected]. To prevent unauthorised access to your personal data, we will verify that you are the account holder before processing your data access request.

3.2. Right to rectification of any incorrect or incomplete personal data

If the personal data we process for you is incorrect, outdated or incomplete, you may request us to rectify, update or complete your missing personal data by contacting us at [email protected]. To prevent unauthorised access to your personal data, we will verify that you are the account holder before processing your request.

3.3. Right to object to the processing of your personal data

In certain circumstances, you have the right to object to our processing of your personal data or request that we restrict processing your personal data by contacting us at [email protected].

3.4. Right to request deletion of your personal data

You may request the deletion of your Angel VPN account and associated personal data by contacting us at [email protected]. Please note that we will verify that you are the account holder before deleting your Angel VPN account and related personal data. You understand that even after the deletion of your account, we may be required to retain some of your personal data on other lawful grounds, including compliance with our legal obligations.

3.5. Right to withdraw your consent

To the extent the legal basis of our processing of your personal data is your consent, you have the right to withdraw your consent at any time. You can opt out of receiving marketing communication from us by clicking the ‘unsubscribe’ link at the bottom of our marketing emails. You can also block the use of our cookies to which you previously consented by accessing your browser settings.

3.6. Right to complain to a data protection authority

Individuals in the UK & EEA have the right to file a complaint against any infringement of their data rights by contacting us directly or, if all else fails, by lodging a complaint with their local data protection authority.

3.7 For users in California

If you are a California resident, you can exercise your rights as provided in the California Consumer Privacy Act (“CCPA”) by contacting us at [email protected]. As per definitions in the CCPA, please note that Angel VPN does not sell, share, lease, or rent your personal information.

Additionally, you may delete your Angel VPN Account for different Angel VPN products as described below. To initiate deletion, please follow these steps, and our support team will follow up with your request shortly:

• AngelVPN Account via AngelVPN app on iPhone: open the AngelVPN app and log into your account; tap on the “Settings” icon on the bottom right corner, tap “Contact Us”, select “Manage the account”, type in “Please delete my account”, and tap “SEND”.

• AngelVPN Account via AngelVPN desktop app on Mac: open the AngelVPN app and log into your account, click on “Help” and select “Email Support”; on our “Contact Us” form, select “Manage the account”, type in “Please delete my account”, and click “SEND”.

Disclosure and Transfer of your personal data

We do not sell or rent your personal data. We only disclose your personal data for the purposes described in this Privacy Policy, including:

4.1. Third-Party Service Providers

We may disclose your personal data to third-party service providers (“Service Providers”) who help us with the performance of our business operations, such as payment processing, emailing tools, analytics, marketing, customer support and other purposes for which your personal data is processed as described in Art. 1 of this Privacy Policy. We may also partner with app stores (“Partners”) to distribute our applications. The app stores may act as independent data controllers of your personal data, and their legal agreements and privacy policies will govern your relationship with them in addition to this Privacy Policy.
As some of our Service Providers and Partners are located outside of the UK and EEA, your personal data may be transferred and processed outside of the country where you reside. If your personal data is transferred and processed in a jurisdiction that is not deemed adequate by the EEA, we will only transfer your personal data to our Service Providers pursuant to appropriate data processing agreements as required by the GDPR. When you use our Service, you acknowledge and agree that your personal data may be transferred and processed outside your country of residence.
Some of the main processors that currently help us with our business operations include: