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Privacy Policy

Effective Date Oct 27, 2024

Dev LLC is the operator of the VPN service “CyberTom” (referred to as “Service”, “us”, “we”, or “our”).

As a privacy service, we acknowledge the importance of ensuring our customers have a full understanding of the personal data we collect, store, and process.

Our systems are created with consideration for your privacy and follow the principle of minimizing data usage. We have made an enormous effort to ensure that this policy is easy to understand and straightforward, allowing you to access necessary information without having to navigate lengthy and confusing legal language.

We do not store records of your VPN usage, internet browsing habits, visited websites, or any actions associated with your VPN account. Furthermore, we do not retain any VPN connection logs or timestamps that correspond to your incoming and outgoing IP address or session length.

This policy is relevant when we are acting as a data controller for the personal data of our website visitors and service users, meaning we decide how and why the data is processed.

This policy does not pertain to any third-party service or product, even if we have a connection to that third-party service or product. Our website contains links to and information about third party websites. We do not have authority over, and are not accountable for, the privacy policies and practices of third parties.

By utilizing our website, services, or products, you are agreeing to the conditions outlined in this policy.

Data Collection:
To enhance your privacy, we only gather the essential personal details needed, which include your email address or phone number. Your email address or phone number is saved in encrypted format on servers that are fully encrypted.

Encryption technology will safeguard any personal data, such as your email address, sent between your device and our web server or from our web server to your web browser. We do not collect or retain personal information such as your name, IP address, physical address, or any other identifying details.

Your email address stored in your account’s Personal Data may be utilized to reach out to you with newsletters, marketing materials, promotions, and other relevant information. Additionally, free trial promotions may utilize personal information. You have the option to stop receiving any or all our communications by clicking on the Unsubscribe link or following the instructions in our emails, or by reaching out to us directly. By creating a CyberTom account, you agree to this procedure.

Information Processing:
We keep a temporary record of connection information for troubleshooting reasons, containing a user’s randomly created username and internally designated (not public) IP address. The log for fixing problems is erased in a secure manner every couple of hours. We intentionally refrain from keeping any additional data to reduce our legal responsibility. We do not track or record your online activities. Recording your browsing behavior with our technical backend is not possible. The usage data is anonymous and does not link back to your actual, public IP address.

After the connection is ended, we will calculate the amount of data you used while connected to the VPN to update the data usage counters. We analyze the total monthly data traffic to uphold a high service standard.

Personal Data:
We might analyze information on how you use our websites (known as “website usage data”). The data from website usage might consist of your IP address, location, type of browser, operating system, where you came from, how long you stayed, how many pages you viewed, and how you navigated the site, along with details on when and how often you visited. The web server logs are the origin of the data on website usage. The usage data can be analyzed to understand how the website and services are being used. Our legitimate interest, specifically in security, monitoring, protecting, and enhancing our website and services, is the legal foundation for this procedure.

Support over email, phone, chat or forms:
We can analyze information in or related to any communication you send us (“correspondence data”). The correspondence information might consist of your email address, the content of the communication, and the communication-related metadata. The metadata linked to messages sent through our website’s contact forms or SMTP protocol will be produced by our website or mail servers. The communication data can be utilized for contacting you and maintaining records. Our main goal is to offer top-notch customer support and enhance our services for you.

Collected Data Processing:
The collected data is utilized for a variety of reasons:
• To deliver, uphold, and enhance our Services
• To inform you of any adjustments made to our Services.
• For you to engage in interactive aspects of our Services if you decide to participate
• To help customers, including sending emails to reset passwords
• To collect analysis or valuable data to enhance our Services or conduct scientific research.
• To keep track of how our Services are being used
• To identify, stop, and resolve technical problems
• To identify and stop fraudulent or criminal behavior.
• To fulfill the obligations of an agreement you have entered with us or to establish an agreement with us
• To fulfill a legal requirement, we are bound by or to safeguard your or another person’s essential interests.
• We will send you updates, exclusive deals, and overall details about similar products, services, and events that match your previous purchases or inquiries unless you choose not to receive them.

CyberTom utilizes your personal information in accordance with the details provided in this policy. Kindly refrain from providing us with personal information belonging to any other individual.

Diagnostics and Crash Reports:
We may gather anonymous crash reports and network diagnostics with your approval. Your VPN usage cannot be linked to this information. Our apps might send:
• Information for diagnosing the connection establishment or failure.
• Tests measuring speed
• Report on crashes

You can decide whether to share this information within the app’s settings.

Data after Cancellation:
When a VPN service account is canceled on our network, all information linked to the account, including the account itself, is removed from our systems.

Customer Data Request by Authorities:
The company is registered in Wyoming. Should CyberTom receive a court order from a valid legal authority with jurisdiction, the company will adhere to it. Nevertheless, the company is not obligated to provide information it does not possess. When a customer registers, we only ask for the bare minimum: a valid email address. Should we ever be obligated by law to maintain a permanent record of our clients’ connections or any additional personal information regarding their network usage, we will promptly inform our clients and take all possible actions to relocate or shut down the service to safeguard the privacy of those who rely on us.

Data Security:
We value the security of your data, however, keep in mind that no method of Internet transmission or electronic storage is completely secure. Although we make every effort to safeguard your Personal Data using standard practices, we cannot ensure complete security.

The servers where we store personal data are in secure facilities, under our operation, and fully encrypted. All data transfer is protected by a minimum of TLS 1.2.

Do Not Track:
We are in favor of Do Not Track (“DNT”). The Do Not Track option in your web browser notifies websites that you do not wish to be tracked.

You have the option to activate or deactivate Do Not Track by accessing the Preferences or Settings section of your browser.

Customer Rights:
Our goal is to provide you with the opportunity to rectify, modify, remove, or restrict the use of your Personal Data by taking appropriate measures.

If it is possible, you have the option to update or delete your Personal Data through your account settings. Should you be incapable of modifying your Personal Data, kindly get in touch with us for assistance in making the necessary adjustments.

If you want to know the Personal Data, we have on you and request its removal from our systems, please get in touch with us.

Under certain conditions, you are entitled to:
• To obtain and get a copy of the Personal Data we have on file for you
• To correct any inaccuracies in the Personal Data stored about you or update any Personal Data stored about you.
• To ask for the removal of Personal Data that is stored about you.
• To limit the handling of your Personal Data
• To oppose our handling of your Personal Data

You are entitled to data portability for the data you share with us. You have the option to ask for a copy of your Personal Data in a frequently utilized electronic format to have control over it and transfer it. Kindly be aware that we may request proof of identity before addressing the inquiries mentioned.

If you believe our handling of your personal data violates data protection regulations, you have the right to file a complaint with a data protection supervisory authority. You can choose to do this in the EU member state where you usually live, where you work, or where the alleged violation occurred. If we process your personal information based on consent, you can withdraw that consent whenever you want. The withdrawal does not impact the legality of processing that occurred before the withdrawal. You can utilize your rights regarding your personal data by sending us a written notice, preferably via email at [email protected].

Service Providers:
We might utilize third-party organizations and individuals to help with our Service (“Service Providers”), deliver the Service for us, perform Service-related tasks, or aid in analyzing the usage of our Services. The types of these services include payment solution providers and email service providers.

These external parties can access your Personal Data as needed to carry out tasks for us and are required not to reveal or utilize it for any other reason.

Payments:
No information about the payments is being stored in our system. Stripe, Inc. (stripe.com) processes or updates the payments with a unique user id for each account.

We might offer other paid services through the Service. In such situations, we rely on external services for handling payments, such as payment processors.

We will not retain or gather your information. The personal information is given to our third-party payment processors who abide by their own Privacy Policy. These payment processors follow the guidelines established by PCI-DSS as overseen by the PCI Security Standards Council, consisting of major brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements aid in guaranteeing the secure management of payment data.

The payment processors that we collaborate with include:
• Stripe Inc Privacy Policy: https://stripe.com/privacy
• PayPal Inc Privacy Policy: https://www.paypal.com/al/webapps/mpp/ua/privacy-full
• Apple Store Privacy Policy: https://www.apple.com/legal/privacy/en-ww/
• Google Play Privacy Policy: https://www.google.com/policies/privacy/

Emails:
CyberTom utilizes Google Workspace, and Mailchimp for sending out your transactional and promotional emails respectively. Mailchimp has confirmed its adherence to the EU-US Privacy Shield Framework. For further information on the Privacy Shield Framework, check out the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/Individuals-in-Europe.

Clients who have subscribed to CyberTom’s $99 Lifetime VPN plan can delete their email address from our database while still being able to access our VPN service ONLY on ONE device for the rest of their life.

Communication with Other Email Providers:
To inquire about technical issues with email traffic between our domains, email providers can reach out to us at [email protected]. This communication is specifically for dealing with delivery issues, resolving problems with deliverability, and ensuring adherence to email communication standards.

Data Transfer:
Your data, like Personal Information, could be sent to and stored on computers in another location with potentially different data protection laws than your own jurisdiction.

If you decide to give us information, keep in mind that we will process the data on the cloud such as AWS, GCP, Azure, and on CyberTom’s Proprietary Distributed Network Infrastructure consisting of thousands of Secure Bare-Metal Servers worldwide, including Personal Data. By agreeing to this Privacy Policy and submitting your information, you are also agreeing to its transfer and processing.

We will do everything needed to make sure your data is handled securely and in line with this Privacy Policy. Your Personal Data will not be transferred to any organization or country without sufficient controls in place for data and personal information security.

Cookies:
Cookies are tiny bits of text that a website sends to your web browser when you visit it. A small data file called a cookie is saved in your browser, which helps the Service or a third-party to identify you and improve your future visits to make the Service more beneficial for you. Cookies are categorized as either “persistent” or “session” cookies. Persistent cookies stay on your PC or mobile device when disconnected, while session cookies are removed upon closing your browser.

Disabling Cookies:
If you want to remove cookies or direct your web browser to remove or reject cookies, please check the help section of your web browser. If you choose to delete cookies or decline them, you may not have access to all our features, store preferences, or view some pages correctly.

Use of Cookies:
When you utilize and log into the Service, we might store several cookies in your browser. Cookies are utilized for the following objectives:
• To allow specific features of the Service to be activated
• For offering analysis
• To save your choices. Both session and persistent cookies are utilized on the Service, with various types of cookies employed to operate the Service.
• Necessary cookies. Cookies can be utilized to retain data that alters the functionality or appearance of the Service, like a user’s language choice.
• Cookies related to accounts. Accounts-related cookies can be utilized for user authentication and to deter fraudulent activity on user accounts. These cookies can be utilized to retain data that alters how the Service operates or appears, like the “remember me” feature.
• Tracking cookies for analysis. Analytics cookies may be utilized to monitor how the Service is used to implement enhancements. Analytics cookies can also be utilized to evaluate users’ responses to new advertisements, pages, features, or functionalities on the Service.

Third-party Cookies:
Apart from our own cookies, we may utilize third-party cookies for tracking usage statistics, displaying ads, etc. within the Service.

Third-party Links:
Our Service may include links to external websites that are not managed by us. By clicking on a link from a third-party, you will be redirected to their website. We highly recommend that you examine the Privacy Policy of each website you frequent. We do not have power over and do not take on responsibility for the content, privacy policies, or practices of third-party sites or services.

Children’s Privacy:
Our Service is not intended for individuals under the age of 18 (“Children”).

We do not intentionally gather personal information from individuals under the age of 18. If you are a parent or guardian and you know that your Children have given us Personal Data, please get in touch with us. If we discover that we have gathered Personal Data from children without confirming parental consent, we will work to delete that information from our servers.

Policy Change:
CyberTom has the right to modify this privacy policy whenever necessary. In these situations, we will make sure to notify you of any changes by prominently displaying them on the CyberTom website for a reasonable amount of time before the new policy goes into effect.

It is important to regularly review this page to make sure you are satisfied with any updates to this policy.

Contact:
Dev LLC owns and runs CyberTom websites and the CyberTom VPN service. We are a Wyoming company, and our registered office is located at 152 North Durbin Street, Suite 308, Casper, WY 82601, with mailing addresses also at 4701 Patrick Henry Dr, Bldg 25, Santa Clara, CA 95054 or 6200 La Calma Dr, Suite 115, Austin, TX 78752. Feel free to reach out to us via email at [email protected] or by phone at (855) CYBR-TOM or (855) 292-7866.

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CyberTom has created one of the most trustworthy privacy and security solutions globally. The company ensures the online anonymity of many customers worldwide. CyberTom is the pioneer in the industry to prioritize privacy as a fundamental human right, ensuring transparency in developing user-focused Cybersafety technology. Using CyberTom VPN to commit illegal activities is strictly prohibited. Engaging in illegal actions remains prohibited, regardless of utilizing a VPN for cover. Dev LLC owns and runs the CyberTom websites and the CyberTom VPN service. We are a WY company, and our office is located at 152 North Durbin Street, Suite 308, Casper, WY 82601 with mailing addresses at 4701 Patrick Henry Dr, Bldg 25, Santa Clara, CA 95054 or 6200 La Calma Dr, Suite 115, Austin, TX 78752. To reach us, you can email [email protected] or call (855) CYBR-TOM or (855) 292-7866.

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