/Privacy Policy – Tornado VPN – Borneh LTD

Privacy Policy – Tornado VPN – Borneh LTD

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Tornado VPN believes in privacy and online freedom and that it should be very clear how we protect and manage your personal information.

The core of our service is the Tornado VPN Private Network which provides private and secure data transmission. If you are using the Tornado VPN Private Browser or Tornado VPN Virtual Private Network (VPN) Service, we route your browser Internet traffic through our network. In each case, our software browser or client establishes and maintains an encrypted tunnel between your browser or device and our network.

1. COLLECTION OF INFORMATION
The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, iOS ad identifier (IDFA), Android ad master identifier, International Mobile Subscriber Identification Number(IMSI), iOS network card (MAC) address, and iOS international mobile device identification code (IMEI) The equipment model, email address, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, etc.

– How we protect your personal information
The Tornado VPN network is a no-log network. Except for the limited exceptions below, we do not collect any information transmitted through our network. More specifically, we do not collect any information regarding the websites you visit or the IP addresses assigned to you when you access the Tornado VPN Private Network, and with respect to our VPN service, we do not collect any data stored on or transmitted from your device, including any data that applications on your device may transmit through our network.

– When will we collect your personal information?
We automatically collect certain non-Personal Information from Users.

For instance, Tornado VPN assigns a unique identifier to each User of the Service, but Tornado VPN does not tie these unique identifiers to the Personal Information of Users. Additionally, any browsing information or other similar information relating to your online activities transmitted by you to our servers when using Tornado VPN is cleared after your VPN “session” is closed.

When you use the Service, Tornado VPN will check your account information (which includes Personal Information) to determine the level of service you have signed up for before establishing your VPN connection. Your account information is not associated with your online activities when using Tornado VPN.

2. USE OF PERSONAL DATA
Product Improvement. We use data to continually improve our products, including adding new features or capabilities.

– How we deal with your private information?
Tornado VPN will only collect personal information needed for it to properly conduct its business and only collect it by fair and lawful means.

– To confirm your VIP identification
When you become a VIP user of the Service, your personal information, E-mail address and IP location address included, will be collected to set a separate VIP account and verify VIP identification.

– To ensure the quality of product
When there is a debug about the product version, we will use E-mail to contact with you, and collect the specific information such as unique device ID, device type, browser type, and operating system type. Those are helpful to speed up solving problems and improve product experience.

– To improve customer service
When we have any problems in specific areas, we will use E-mail to communicate in order to get feedback and best suggestion. With the fluent communication, it is helpful to get better customer support with you.

– To study and analyze
When you become a user of the Service, we will collect the statistic about users’ behavior and location. By learning and analyzing the statistic, we will improve the service and product to be better.

In the course of interacting with Tornado VPN, we may need specific information from you to enable Tornado VPN to solve the problem and improve the service as soon as possible. Please note that access to your personal information is in accordance with Tornado VPN’s retention and access policy.

3. THE STORAGE AND SHARING OF PERSONAL DATA
In order to fulfill our contractual obligations to you, that is: to provide you with product services, your personal information will be processed on our servers. Our servers are located in Singapore.

To improve our product and provide you better service, we also share personal data with vendors or agents working on our behalf for the purposes described in this privacy policy. For example, companies we’ve hired to provide data analytical services may need collect and access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements.

4. LGGAL BASIS FOR DATA PROCESSING
We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

5.INTERNATIONAL TRANSFERS OF PERSONAL DATA
Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries such as the People’s Republic of China or Singapore. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

6.YOUR RIGHTS
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Requests should be submitted by contacting us through masterappfeedback@gmail.com. If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law. We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

Tornado VPN user understands that the present Privacy Policy is subject to immaterial changes made by Tornado VPN at any time at its sole discretion, and you agree to be bound by these modifications, changes and/or revisions. If there is any material change in the content of this Privacy Policy, we will notify you and regain your consent before the change takes effect.