Privacy Policy

You have legitimate concerns about privacy and therefore we expressly describe all processing of personal data done by us. We want you to understand what limited information we collect and what may happen to that information when you use any of Activate Technologies LLC's services.

This document (hereinafter, the “Privacy Policy”) explains the privacy rules applicable to all information collected or submitted when you access, install or use Initiate VPN Limited services.

Our top priority is customer data security. We process only minimal user data – only as much as is absolutely necessary to maintain our services. All definitions and terms used in this Privacy Policy are defined in our Terms of Service.

By visiting the Activate Technologies LLC website, by submitting your personal data to Activate Technologies LLC, also by accessing, installing and/or using Activate Technologies LLC services you confirm that you have read and agree to be bound by this Privacy Policy and that you enter into a legally binding relationship with Activate Technologies LLC, a corporation registered in the Republic of the Seychelles (hereinafter, “Initiate VPN”, “Activate”, “we” or “us”). The data controller of your personal data, as described in this Privacy Policy, is Activate Technologies LLC.

If you disagree with the rules of this Privacy Policy, please do not use Initiate VPN’s services. If you have any questions about this Privacy Policy or your privacy, please contact us.

Processing of your data

Initiate VPN processes user data only to a very limited scope – only as much as it is absolutely required for provision of Initiate VPN services, processing of payments for Initiate VPN services, and functioning of the Initiate VPN website and mobile applications.

Personal data is processed by Initiate VPN automatically and manually. Unless expressly noted otherwise, Initiate VPN or a designated subsidiary in your country shall act as the responsible personal data controller for any data processed. Initiate VPN uses third-party data processors only for processing of payment data, emailing services, marketing and basic website and app analytics.

Data Collected

If you choose to create a user account, you must provide the following basic information:

  • Email address
  • Name
  • Billing information

We ask for your email address as part of your registration. That ensures that we can communicate with you when we have any announcements to make, service updates to advise, or errors to report. A valid email address is also needed to retrieve lost passwords.

VPN Services

Initiate VPN guarantees a strict no-logs policy for Initiate VPN VPN services, meaning that activities conducted using Initiate VPN services are provided by automated technical processes and are not monitored, recorded, logged, stored or passed to any third-party.

We do not store connection time stamps, session information, used bandwidth, traffic logs, IP addresses, or other data. From the moment a Initiate VPN user turns on the Initiate VPN software, their internet data becomes encrypted. Any online traffic coming from a user’s device is no longer visible to ISPs, third-party snoopers, or cyber criminals. Further, Initiate VPN has a strict no-logs policy when it comes to viewing and monitoring user activity online.Anyone may browse our website, and install Initiate VPN applications (mobile or otherwise) without signing up for Initiate VPN services. However, the functionality of Initiate VPN services will be limited or absent. If you want to engage full functionality of Initiate VPN services, you need to create a user account and provide basic personal data indicated below.

Payment data

In addition to the conventional payment methods, such as credit card, our payment processing partners process basic billing information for payment processing and refund requests. You must maintain this information is current, truthful, complete, and accurate. You warrant that you are authorized to provide such information.

You authorize us to verify your information at any time. If it is found to be untrue, inaccurate, not current, or incomplete, we retain the right, in our sole discretion, to suspend or terminate your user account and your access to Initiate VPN services. In order to maintain the service, Initiate VPN also processes limited technical information, which sometimes may be considered personal data. This information is used for improving the functionality and usability of our website and Initiate VPN services.If you decide not to provide this limited information, we may not be able to provide you with the full scope of Initiate VPN services.

Customer service information

Initiate VPN’s services may store inquiries and communications with users through the Contact Us and Community Area pages, as well as 3rd party software designed to track customer issues.

Targeted Advertising

We may partner with third party advertising networks that collect unique device identifiers (UDIDs), browser type, operating system, time zone, country, referring pages, and other information through the use of cookies, and pixel tags on Initiate VPN websites, apps, emails and on third party websites and emails. They use this information to provide you with advertisements that are customers to your preferences, including for companies that are not affiliated with us. You may see these advertisements on Initiate VPN Websites and third party apps and websites, across different devices you use. We may use this process to help us manage and improve the effectiveness of our marketing efforts. If you would like to learn more about the third party advertisers that may be aware of the fact you visit Initiate VPN websites or use our apps, and to understand your opt-out choices, please visit the website of the National Advertising Initiative here. Please note this does not opt you out of being served advertising. You will still receive generic ads.

Please understand that Initiate VPN does not control these third party cookies, and you should check the privacy policies of third party advertising networks to see whether and how they use cookies.

Personal data of underage persons

Persons younger than 18 shall not use Initiate VPN services and provide any personal data to us without the supervision of parents or guardians. Based on the above, it is presumed that any person using Initiate VPN services and supplying personal data to us is at least 18 years of age. If a person younger than 18 years of age or a person supplying wrongful data become known to Initiate VPN, such person and all their data may be immediately and without any notice withdrawn by suspending their access to Initiate VPN services.

Grounds for data processing

Your personal data is processed for the purpose of providing you the best Initiate VPN service under the legal basis of performance of the contract between you and Initiate VPN, as provided in our Terms of Service. Initiate VPN may process your personal data (email address) for direct marketing purposes in the following cases: when we obtain your consent to such processing (the legal basis for processing, in this case, is your consent) or when applicable law permits us to contact you without a separate consent (under the legal basis of a legitimate interest).

Initiate VPN may share your data with third-parties and partners as outlined in this policy.

Sharing Your Personal Data

We will not share your personal data with any third-parties except as expressed in this Privacy Policy.

Service providers. We use third-party service providers to help us with various platform operations, such as payments, automation of emails, Websites and app diagnostics, analytics, and others. As a result, some of our service providers may process personal data.

Some of our main service provider include:

  • Live chat and support service platform, e.g., Zendesk (provided by Zendesk Inc.)
  • Marketing, application analytics and diagnostics, e.g., Google Analytics, Google Ads (provided by Google)
  • Payments processing, e.g., Stripe (provided by Stripe Payments Inc), Paypal (provided by Paypal Holdings Inc.) , and others.
  • Initiate VPN partners. Sometimes our partners will be independent data controllers of your personal data. In such cases, the policies established by them (e.g., terms of service and privacy policies) will apply to those relationships. In other cases we may work with partners as joint controllers, which means that we jointly define the purpose and means of data processing with them. Both joint controllers are then responsible for the data processing and its compliance with applicable privacy laws.
  • We also partner with third parties to display advertising on our Websites or to manage our advertising on other sites, including social media. These ad partners help us deliver more relevant advertisements and promotional messages to you, which may include behavioral, contextual, and generic advertising. We and our advertising partners may process certain personal data to help us understand your preferences so that we can deliver advertisements that are more relevant to you.
  • Your personal data may be processed in any country in which we engage service providers and partners. When you use our Services and Websites, you understand and acknowledge that your personal data may be transferred outside of the country where you reside.

    • Your personal data protection rights

    You may request us to inform you about the personal data that we have collected about you, to request any changes or correction of inaccurate information, to object to certain processing of personal data (e.g. for marketing purposes), to provide you with a copy of your personal data in a structured, commonly used and machine-readable format, to transmit (if technically feasible) your personal data to another controller, or to erase your personal data. You also may request to restrict the processing of your personal data (if required by a law in your jurisdiction such as the General Data Protection Regulation (the “GDPR”)), the California Consumer Privacy Act (CCPA) or others.

    In cases where your personal data is processed on a separate consent basis, you have the right at any time to withdraw your consent to the processing of your personal data by contacting us. If you disagree with your data processing by Initiate VPN, you are free not to use the Initiate VPN Service, and to discontinue using it at any time. You may request us to discontinue processing of 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 Initiate VPN services (e.g., final settlement, or deleting all personal data based on your email address), or finalizing Initiate VPN’s legal relationship with you (e.g. accounting, invoicing, processing refunds). Due to technical reasons (such as backup copies of the databases) your personal data may be finally deleted only within 60 days or longer if it is mandated by statutory requirements. If you wish to use Initiate VPN services again, you will have to accept and agree to this Privacy Policy anew.

    Opt-out

    If you wish to unsubscribe from our communication, you can opt out at any time by clicking the “unsubscribe” link at the bottom of each email or contacting us.

    You can control the use of cookies at the individual browser level on your device. To disable cookies, follow your browser’s instructions on how to block or clear cookies.

    If you do not agree with the processing of your personal data by Initiate 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 finalizing other Initiate VPN’s legal relationship with you (e.g., record keeping, accounting, processing refunds). Please note that we or our third-party service providers may be obliged to retain your certain personal data as required by law.

    To raise any other questions, concerns, or complaints about our privacy practices or about our processing of your personal data, please contact us as provided on our website.

    Term for storing personal data

    Initiate VPN stores limited personal data for the whole period during which Initiate VPN services are used and for no longer than necessary and in no case more than 2 years after last use of the app and/or the services. You may contact us at any time and request that you be provided with a detailed list of the personal data that has been collected for you. If requests to see said personal data are made more than once per three month period and the minimum amount as required under the GDPR, CCPA or other statute, then we can refuse or charge you a reasonable fee for compliance. In complying with the foregoing, we may request proof of your identity. We will take no longer than 30 days, the maximum amount of time allowed under the GDPR to provide this data to you. We never collect any biometric data (as defined in the GDPR), under any circumstances.

    Cookies

    Please see our Cookie Policy for more details.

    Other Terms

    If the data is processed by a designated subsidiary, agent, or supplier in your country, then the domestic law of your country may be applicable at our discretion. Initiate VPN would like to remind you that you are responsible for the security of your data. We ask you to be careful when using and storing personal data containing files on your devices, as well as when using the devices themselves. Please ensure that nobody accesses and uses your devices without your consent.You shall be extra careful to not disclose your personal information to unrelated third-parties, since such information may be used in different ways and against your interests, including activities such as fraud, invasion of privacy, identity theft, etc.In order to ensure security of personal data, Initiate VPN employs various administrative, technical and physical security measures. However, it is your responsibility to exercise caution and reason when using Initiate VPN services. You will be personally responsible if such action violates any third-party’s privacy or any other rights, or any applicable law. Under no circumstances will Initiate VPN be liable for the consequences of your unlawful activities, your willful and negligent activities violating applicable laws or third-party rights, as well as any circumstances, which may not have been reasonably controlled or foreseen.

    This Privacy Policy may be modified and updated at any time, at our sole discretion, for any or no reason, and without liability, as indicated below. The date of the most current wording of the Privacy Policy is indicated at the top of the text. We ask all users to ensure that they are familiar with the most current wording of the Privacy Policy. The amendment of the Privacy Policy may be communicated to you by sending an email and/or by publishing the updated Privacy Policy on the Initiate VPN website. Please consider reviewing the Privacy Policy each time you use Initiate VPN services. Updates of the Privacy Policy come into force as of the moment when they are published.You may not assign or transfer your rights or obligations under this Privacy Policy to any third-party. Please contact us if you have any questions about our Privacy Policy or you want to enforce any of your rights related to your privacy.

    Updates to the Privacy Policy

    We develop our Services and Websites introducing new features or modifying current ones constantly. Therefore, we may need to amend the Privacy Policy from time to time. If the amendments to the Privacy Policy materially affect the activities of our processing of your personal data, we will notify you in advance of such changes by reasonable means (e.g., notification through the respective applications, our Websites, or via email), and we will always indicate the date of the last update. Unless it is stated by us otherwise, each update of the Privacy Policy comes into force as of the moment when the amended Privacy Policy is published on this Website. You are expected to check this Privacy Policy regularly so that you are familiar with the most current wording of the Privacy Policy. Your continued use of the Services and Websites will be deemed acceptance thereof.