PRIVACY POLICY

Last Modified: September 29, 2023

This Privacy Policy explains how VERİTY BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ, address: Vişnezade Mah. Süleyman Seba Cad. No: 79, İc Kapi No: 1 Beşiktas / İstanbul - Türkiye processes your personal data when you use our Services or interact with our Website or our iOS and Android apps. The Privacy Policy will remain in effect until a new policy supersedes it. We may choose to update this policy at our discretion, so you should check this page periodically as the terms may change from time to time. Your continued use of the Website and our Services and our iOS and Android apps will constitute your acknowledgment of the policy in its current version and your understanding of the terms of the policy.

VERİTY BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ is a company and committed to protecting your privacy. This Privacy Policy describes how Verity LTD ("VPN 111", "Verity LTD", "Verity", "VERİTY BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ", "we" or "us") controls ("collect", "use", "disclose" or "protect") our users' ("your") personal data and how can our users control their data. This Policy applies to all services (collectively as the "Service") offered by VPN 111 (Software versions like Android, iOS) and VPN 111 official websites.

Your consent is the legal basis for data collecting and processing. By visiting or using the Service, you consent to the terms set forth in this Privacy Policy.

As an internet privacy & security service provider, we make sure your privacy is our primary concern, and we will be 100% transparent with our users. We believe the relationship between the users and us is built on trust, and trust is built on the truth. To offer better clarity to you, let's start with three points:

We do not log how you utilize VPN connection, which means we do not see the applications, service or websites you use personally while connected to our Service nor do we store them.

We do not store your original IP address or the server IP address that you connect to which means we cannot share it to anyone no matter what happened.

We will not sell, use, or disclose any personal data to third parties not mentioned in this Privacy for any purpose.

Our guiding principle toward data collection is to collect only the minimal data required to operate a world-class VPN service at scale. We designed our systems to not have sensitive data about our customers; even when compelled, we cannot provide data that we do not possess.

Important Note

The summaries here at the top of each section are for easy referencing; they are not meant to have any legal effect or in any way substitute the text of the Privacy Policy, which should be read and understood in full detail.

Table of Contents

1. What data do we collect and how?
2. Why Do We Collect Your Data?
3. Sharing Your Personal Data
4. Security of your Personal Data
5. Your rights and Control
6. Data Retention
7. Third-Party Websites
8. Disclosure of your information
9. Children's Privacy
10. Policy Updates
11. Contact

1. What data do we collect and how?

We keep our Services logs-free. We don't collect any information that could lead us to know what you're up to online.

VPN 111 respects your privacy, therefore we are committed to not process any information related to the online activity of our users. VPN 111 is based in the jurisdiction, which does not require information storage or reporting. We do not collect any information about what you do online (your visited IP addresses, browsing history, session information, used bandwidth, connection time stamps, network traffic or any other similar information).
Our servers do store information about your connection to a particular VPN server (user ID and connection time stamps), but this information is automatically deleted within 15 minutes after termination of your session. And be assured that no information is stored about the websites you visit.

VPN 111 uses your personal information only for the purposes listed in this Privacy Policy, and we do not sell your personal information to third parties.

When you visit our Website or navigate within our app (collectively referred to as 'Website'), we collect and use some information to improve the performance of our Website.The information we collect on our Website may include anonymous traffic informations provided by the host or similar provider of such information (e.g. Google Analytics) that does not personally identify you. This information is statistical and includes information about which pages on VPN 111's Website visitors visit and how long visitors stay on a particular page. It also provides information about what browser, network, or device is used to visit our Website. Also, when you visit our Website, we may retain your IP address and a unique identifier of your device. This helps us identify problems with our server, to administer our Website, or to display the content according to your preferences.The legal basis for such processing is our legitimate interest to analyze and improve the performance of our Website and user experience. That does not mean that we track your online activity while you use our Services.

If you want to remove information you have already submitted to us, please contact us at vpn111@troophy.zendesk.com.

Right to Access, Rectification, Erasure, Portability, and right to lodge a complaint: Through the Service, you can directly access, edit, delete or export personal data processed by the Verity LTD in your use of the Service.
If your account has been suspended for a breach of our terms and conditions, and you would like to exercise the rights related to your personal data, you can make a request to our support team.
In case of violation of your rights, you have the right to lodge a complaint to the competent supervisory authority.
Data retention: We retain essential data (such as username, email, billing information) on active accounts in order to provide services. This data is deleted when your account is deleted.

Information collected on our Websites
Access logs: As most websites on the internet, our Websites collect access logs (such as IP address, browser type, 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.
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 Website's to operate smoothly; others are used to improve Website's functionality, analyze 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.

Referrals data : Information for participating in referral programs: Participation in referral programs maintained by VPN 111 requires referrers to submit personal information (e.g., full name, e-mail address, phone number, relationship with the referred party) about themselves and a referred party so that VPN 111 could i) reach out to the referred party; ii) 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 VPN 111, including informing third parties that they are providing referred parties’ personal data to VPN 111 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.

We store your Personal Data only as long as it is necessary for the purposes for which it is collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We erase or destroy the records containing Personal Data when they are no longer required; this will be done in ways that will ensure your continued privacy.

2. Why Do We Collect Your Data?

We collect the Data for the purpose of:
Service improvement and personalization of the user experience on VPN 111
The proper administration of our Website and business
The performance of the contract between you and us and/or taking steps, at you request, to enter into such a contract
Scientific research, fraud detection/prevention and improvement of the Service
To notify you of our new services or changes to our existing Services
To send you technical or service-related communications
To enforce the Terms of Service
Customer Analytics

3. Sharing Your Personal Data

We do not share, sell, rent or trade your Personal Data with third parties other than as disclosed within this Privacy Policy. For the purposes of allowing employees with cross-group responsibilities to operate, we may communicate your Personal Data to a member of our group of companies ensuring at all times the same standards of protection and only insofar as reasonably necessary for the purposes set out in this Policy.
Furthermore, we may share certain Personal Data with trusted vendors to carry out a transaction you have requested
In order to assist you if you have questions while using our Website or regarding your order and provide comprehensive customer support, we offer the possibility of online chat. For the use of such online chat, you will be requested to provide personal data such as name and email. Our online chat is offered through Zendesk that will have access to collect and proses such personal data solely for the purpose of facilitating communication with you and record-keeping (https://www.zendesk.com/company/privacy-and-data-protection/). 
We may further collect and possibly share your Personal Data to enforce the Terms of Service. This may be done to prevent a crime or violation of our Terms of Service or to help solve a transgression that has been committed.
We also reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.
Lastly, we may share Non-personal Data associated with the use of our Website and the Services with 3rd part suppliers for the purposes of optimization of our Website and Services as well customer analytics and fraud prevention (e.g. Appsflyer, Google etc). These third parties will use Non-personal Data and/or Personal Data relating to your use of our Website to evaluate your use of the Website, compile reports on Site activity and provide other Site activity and internet related services, all in accordance with their applicable privacy policy. 

4. Security of Your Personal Data

We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. If you have reason to believe that your interaction with the Website is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.
During the development of the Service and the selection of its service providers, VPN 111 has paid attention to providing a high degree of safety:
All data processing centers with which VPN 111 cooperates pass through a compliance process. VPN 111 has generally Root Access to all its servers and administers them itself.
If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse our Service or acted in an inappropriate manner, please contact us directly at vpn111@troophy.zendesk.com. Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you immediately through your account or the Website or, if technically possible, by sending you an email.

5. Your rights and Control

Your principal rights under data protection law in relation to your Persona Data are:

the right to access and information which is provided to you through your account;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data. Depending on your relationship with us, these choices and controls may include, access to the Personal Data collected about you that we hold; correcting, updating or deleting the information associated with you that we hold; and in the event, you wish to opt out from the data collection or you are not able to exerciser your rights through your account please contact us at: vpn111@troophy.zendesk.com. In the event you make such a request, note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

How to Exercise the Right to Access, Rectification, Deletion, and Restriction

Send an email to vpn111@troophy.zendesk.com

You can use the contact ways to request access to, receive, restrict, or request deletion or rectification of Personal Data held about you by VPN 111.

To protect your privacy, VPN 111 requires you to login to your account with a username and password before granting you access to or allowing you to make any changes to your Personal Data. VPN 111 makes good faith efforts to provide you with the ability to delete your Personal Data, however there may be circumstances in which VPN 111 is unable to delete all your Personal Data. For example, we are unable to delete it where we are legally required to keep it, including where we need it to continue to offer you the service.

If VPN 111 determines that your Personal Data cannot be deleted, we will explain why and provide a contact for further inquiries.

If you have any questions about our privacy practices and this Privacy Policy, please contact VPN 111 by email at vpn111@troophy.zendesk.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Users in the European Union:

This section applies to individuals in the European Union and to individuals in other countries whose data privacy laws are similar to GDPR.

Your Rights

As a Data Subject you have rights under the GDPR. These rights can be seen below. VPN 111 will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

(Chapter 3 of the GDPR) each Data Subject has eight rights. These are:

1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
2. The right of access; this is your right to see what data is held about you by a Data Controller.
3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called 'the Right to be Forgotten'. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
5. The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
6. The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
7. The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
8. Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.

Legal Basis

VPN 111 is committed to user privacy globally, and our existing practices reflect that through minimal collection of data and ensuring users have control over their personal information. The General Data Protection Regulation (GDPR) of the European Union (EU) requires us to outline those practices in a specific manner for users in the EU.

In line with the GDPR, we collect and process the data outlined in this Privacy Policy on one of the following bases, depending on the circumstances:

1. For the purposes of fulfilling our contractual obligations to users, including:

Providing users with the Services and Apps they have requested.

Managing user subscriptions and processing payments.

Providing customer support.

2. For a legitimate interest associated with the operation of our business, including:

Enhancing the quality, reliability, and effectiveness of our Site, Services, and Apps.

Communicating with customers to provide information and seek feedback related to our Services and Apps.

You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at: vpn111@troophy.zendesk.com (Please note that we may need one month or longer to respond)

Users in California

VPN 111 does not share information that identifies you personally with non-affiliated third parties for our own marketing use without your permission.

California Consumer Privacy Act

Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Users in Nevada

VPN 111 does not sell information that identifies you personally with non-affiliated third parties. X-VPN will not sell or trade Personal Data for commercial purposes.

6. Data Retention

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion as detailed above. Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements.

7. Third-Party Websites

The Site may contain links to external websites that do not fall under VPN 111's domain. VPN 111 is not responsible for the privacy practices or content of such external websites. 
Links to other websites : Our Websites may include links to other websites (e.g., social media websites) whose privacy practices may be different from ours. If you access any of those websites via such links and/or submit your personal data to any of those websites, your personal data is processed by the procedures established by them and governed by their privacy policies. We encourage you to carefully read the privacy policy (or other respective privacy notice) of any 
website you visit.

8. Disclosure of your information

We will only disclose the limited user data we possess when compelled by law for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security. Foreign authorities data requests must be approved by competent Turkey authorities.
Under US law, it is obligatory to notify the target of a surveillance request, although such notification may come from the authorities and not from the Verity LTD.

9. Children's Privacy

You represent and warrant that you are at least 16 years of age and of legal competence to use our Service. If you are under 18, please be sure to read the Agreement with your parents or legal guardians. We do not use the Service to knowingly solicit data from or market to children under the age of sixteen (16). We request that such individuals do not provide Personal Data through our services. If you become aware or have any reason to believe that a child under the age of 13 has shared any information with us, please contact us at: vpn111@troophy.zendesk.com and we take reasonable steps to ensure that such information is deleted from our files.

10. Policy Updates

If we decide to make changes to our Privacy Policy, at our sole discretion, Such changes and updates will be effective immediately upon the display of the revised Privacy Policy. Thus, we encourage you to check this Privacy Policy regularly for updates, so that you are fully informed on how your data is collected and used by the Verity LTD and your related rights. The last revision date will be reflected in the ''Last Modified'' heading. Your continued use of the Services following the display of such amendments constitutes your acknowledgement and consent to such amendments to the Privacy Policy and your agreement to be bound by the terms of such amended policy.

If we make material changes to this Privacy Policy, we will notify you through the account or the Website and make best efforts to notify you via email, or by means of a notice on our home page prior to the change becoming effective.

11. Contact

If you have any questions regarding our Privacy Policy and how we handle your information, please feel free to contact Verity LTD at the following email address: vpn111@troophy.zendesk.com
VPN 111 Website: https://vpn111.net/

©2023 VERİTY BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ

Visnezade Mah. Suleyman Seba Cad. No: 79
Ic Kapi No: 1 Besiktas/Istanbul - Turkiye

https://www.verityapps.co/
t: +90 212 4001272