Welcome to the Presto VPN iOS application and thank you for your interest in this Privacy Policy!
We know that the handling of your personal data is important to you. For this reason, we take the greatest possible care when handling your personal data and thus ensure a high level of data security. We respect the personal rights of our users and are aware of the importance of protecting the personal data we receive from you.
This Privacy Policy contains information about our data protection practices and measures as well as the rights to which you are entitled within the framework of the Turkish Law on the Protection of Personal Data No. 6698 (the “PPD”) and the EU`s General Data Protection Regulation (“GDPR”). Given the similarities between the PPD and the GDPR, no conflict should arise pursuing a uniform approach. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your personal data.
The Controller
The controller within the meaning of the PPD and the GDPR for the processing of personal data is:
Esinti Giyim Sanayi Ve Ticaret Ltd.
Adress: Feriköy Mahallesi Fırın Sokak No:69/2 Bomonti Şişli İstanbul TURKEY
E-Mail: info@esintilimited.com
If you have any questions about the processing of your personal data, as well as your rights regarding data protection, please contact us.
Where this Privacy Policy applies
This privacy policy applies to the Presto VPN iOS applications (“the App”).
When designing the APP, we have made sure that as little as possible information that directly identifies you is collected. As however some countries including the European Union, have a broad definition of personal data this policy covers it. In this sense we would need to first of all explore the definition of personal data.
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We do NOT log your VPN sessions, browsing behavior, the websites you visit, or any other activity related to your VPN connection. In addition, we NEVER store VPN connection logs and timestamps that associate your incoming and outgoing IP address or session duration.
Legal bases for processing
The processing of your personal data may be based on the following legal grounds:
· contract, insofar as the processing of personal data is necessary for the performance of a contract, e.g., if you use the App (Art. 6 (1) b) GDPR). The same applies to such processing operations that are necessary for the performance of pre-contractual measures, for example in the case of enquiries about the App.
· legal obligation, insofar as we are subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations (Art. 6 (1) c) GDPR).
· legitimate interest, applies on the basis of our legitimate interests, e.g., when using service providers as part of the App (Art. 6 (1) f) GDPR). Our interest is directed towards the use of a user-friendly, appealing, and secure presentation as well as optimization of the App, which serves our business interests as well as meeting your expectations.
What are your rights?
The PPD grants the following rights:
The GDPR grants the following rights:
To assert these rights, please contact us at any time using the details provided. You also have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority.
Exercising Your Privacy Rights
To exercise your rights, please contact us. In accordance with the PPD/GDPR, we will need to confirm your identity to process your requests and we may require you to provide information associated with your account or transactions with us, or to provide government identification, signed declarations and other proof of identity.
Accuracy and updating your information
If you believe that the personal data, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or withdraw your consent, please contact us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of Personal Data, notably where such requests would not allow us to provide our service to you anymore.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation.
The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process.
You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Collection of Personal Data
Personal data may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our APP. As indicated above we have made sure that as little as possible information that directly identifies you is collected.
When you contact us
If you contact us, your transmitted personal data will be automatically stored for the purpose of processing the request or contacting you. We delete the data accruing in this context after the storage is no longer necessary for the processing of your request or restrict the processing if there are legal retention obligations. The legal basis for processing is our legitimate interest and/ or a contractual or precontractual measure.
Automatically collected data
a) Downloading the APP
The APP can be downloaded from the Apple App service "App Store" a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP.
Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.
b) Installing the APP
As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
c) Starting the App
Every time you start the APP, your data is synchronized, and your device communicates with our server through a signed token. The transmission takes place automatically and is a prerequisite for the secure functioning of the APP and is therefore mandatory.
d) Device information
We or rather Apple on our behalf collects information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID).
Firebase
We use the Google Firebase developer platform and related features and services provided by Google Inc and Google Ireland Limited. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase developer platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy
We use the following Google Firebase services in our app:
· Firebase Crashlytics.
By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes.
Google Admob
Our App is build using the Freemium Model. As such, the APP uses the Google Admob service to display ads. Ads are personalized based on the device you are using. You can disable this via the settings on your device. Google may use the advertising ID of your device, as well as cookies and/or similar technologies, to collect personal data for the purpose of generating and displaying personalized advertising. More detailed information about what data Google collects and how it is processed can be found here and how to opt-out of personalized ads see here.
Advertising
Advertisers and third parties also may collect information about your activity on our APP, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our APP and on third-party sites and applications.
You can opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.
RevenueCat
For the management and analysis of in-app purchases, the APP uses the product RevenueCat from Revenue Cat, Inc. The transfer is carried out in accordance with the provisions of Art. 46 GDPR. You consent to the collection of data by the APP and its transmission to RevenueCat. If the storage of the provided data by the third-party provider is not desired, the use of the APP is to be refrained from.
How we use information?
The main reason we use your data is to deliver and improve our services as follows:
How long do we store your data?
We keep your personal data only as long as we need it for legitimate business purposes and as permitted by applicable law. Further and to protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your data upon deletion of your account (following the safety retention window), unless:
Keep in mind that even though our APP is designed to carry out data deletion processes according to the above standards, we cannot promise that all data will be deleted within a specific time-frame due to technical constraints.
Duration of data storage
In general, your APP data is saved and stored on our secure servers operated by on our secure servers using DigitalOcean and Amazon AWS. Accordingly, both restricts access to a select employees who have a business purpose to access personal data, logs employee access to systems that contain personal data and only permits access to personal data by employees who sign in with 2-factor authentication.
In addition, we only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes. We would like to point out that the USA is not a safe third country in the sense of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g., intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.
How do we protect your data?
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal data. As with all online technology, we take steps to secure your data, however we do not promise, and you should not expect, that your personal data will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.
Further, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
How we share your data?
We may disclose your personal data to third parties:
We may also disclose your personal data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the APP, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity.
Personal data and children
The services available on our website are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact. The parent or guardian will be provided with (i) information about the specific type of personal data being collected from the minor, (ii) the purpose for which it will be used, and (iii) the opportunity to object to any further collection, use or storage of such information. We comply with youth protection laws.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case as described above, the provision of certain personal data may be necessary for the provision of the services. If you do not provide us with this personal data, we may not be able to provide the requested service.
Push messages
When using the app, you will receive so-called push messages from us, even if you are not currently using the app. These are messages that we send you as part of the performance of the contract, but also service-related notifications and advertisement. You can adjust or stop receiving push messages at any time via your device settings of your operation system.
Authorizations and Access
We may request access or permission to certain functions from your mobile device (Access to VPN configurations and Push notifications). The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can change your permissions at any time via the Settings Menu of your operation system.
Uninstall
You can stop the collection of information by our APP by uninstalling it using the standard uninstall procedure for your device.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Changes
Because we’re always looking for new and innovative ways to improve our APP, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details:
Esinti Giyim Sanayi Ve Ticaret Ltd.
Adress: Feriköy Mahallesi Fırın Sokak No:69/2 Bomonti Şişli İstanbul TURKEY
E-Mail: info@esintilimited.com
If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.
This Privacy Policy was last updated on Tuesday, September 20, 2022
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