Privacy policy

This Privacy Policy describes how That VPN. ("ThatVPN") handles your Personal Data when you use our services ("Services"). By using our Services and/or registering for an account, you are accepting the terms of this Privacy Policy and our which are integrated here by reference. ThatVPN is a global company. Although our physical servers are located in many different countries around the world, ThatVPN does not store Personal Data outside of USA’s physical borders. By using our services, you authorize ThatVPN to use your information according to USA's laws, regardless of which country you are located in.

If you have any questions or comments about this Privacy Policy, please contact us at: info@thatvpn.com SUBJECT: Privacy

1. Personal Data Collection and Use

As a provider of an online privacy service, we ultimately strive to collect the minimal amount of information required to operate our service. This often means difficult trade-offs between the information we collect and the performance of our service. We believe in an open dialogue because this Privacy Policy is an evolving document. We welcome your thoughts and feedback on how we're doing.

1.1 What is Personal Data?

As described below, "Personal Data" means any information relating to an identified or identifiable natural person ("Individual") and includes information provided by you while using our Services. If we use or store Personal Data with information that is non-personal, we will consider the combination as Personal Data. We strive to collect the minimum amount of information required to operate our service.

1.2 Account User Data

When you create or update your ThatVPN user account, we collect and store this "Account Data". The Account Data stored is listed below in its entirety:

Account Data
What do we use it for?
  • ● Email address
  • ● Marketing, communications, purchase receipts and occasional product news
  • ● Twitter ID (optional)
  • ● Completion of our Twitter promotion
  • ● Email confirmed
  • ● Confirmation that your email address is valid
  • ● Paid user
  • ● Provide paid users with unlimited data
  • ● Paid user expiry date
  • ● Provide paid service until this date
  • ● Example Trade-off: Collecting your name
1.3 Operational Data

ThatVPN also collects and stores "Operational Data" required to operate our Services. This is data that we collect and store when you connect to our network. Operational data is listed below in its entirety:

Operational Data
What do we use it for?
  • ● OS Version e.g. iOS 7
  • ● User support, troubleshooting and product planning
  • ● ThatVPN App Version e.g. PC version 2.1.1
  • ● User support and troubleshooting
  • ● Active this month e.g. 1 or 0
  • ● Customer satisfaction, support, network demand planning
  • ● Total data used this month e.g. 22.34 GB
  • ● Customer satisfaction, support, network demand planning, granting free user data
  • ● Operational events e.g. Created an account, complete Twitter bonus, made a payment, upgraded to paid subscription, online ad referrals
  • ● Troubleshooting account and payment related issues and tracking where sales come from; these events are not related to the time and activity of VPN usage
  • ● Example Trade-off: Selecting an anonymous usage metric

Some data is used to ensure customer satisfaction.

1.4 Personal and Financial Data Collected at Payment

Making a purchase with a credit card on any service will result in Personal Data being exchanged with payment processors.

Credit Card Transactions

ThatVPN processes credit card payment information securely. Credit card processors may store Personal Data associated with financial transactions outside of the United States of America’s borders.

When you pay with credit card, ThatVPN stores the following information:

Payment Data
What do we use it for?
  • ● Cardholder last name e.g. Smith
  • ● For use in credit card fraud prevention
  • ● Date of card use e.g. 2014/01/01
  • ● For use in credit card fraud prevention
  • ● Last four Numbers of Credit Card e.g. 5555
  • ● For use in credit card fraud prevention
  • ● ThatVPN does not store, but can securely login and view the following information through our third party payment processors when applicable.
Payment Data
What do we use it for?
  • ● Card billing address
  • ● For use in credit card fraud prevention
  • ● Card expiry
  • ● For use in credit card fraud prevention
  • ● Last four Numbers of Credit Card
  • ● For use in credit card fraud prevention
  • ● Session information
  • ● For use in credit card fraud prevention
  • ● ThatVPN never stores your complete credit card number or your location at time of payment. To keep your payment information secure, we adopt all available security and multi-factor authentication measures available from these providers.
  • ● ThatVPN operates exclusively with PCI compliant payment processors. Only our payment processors have the ability to collect, use and access your full credit card information and other financial information. They can use this information solely for the purpose of charging and invoicing you for our (paid) Services.
  • ● Example Trade-off: Fighting Credit Card Fraud
Some data is used to prevent purchase fraud.

In building our website and apps, we have tried to limit the number of services with access to store cookies in your browser. There are currently three third-party services with this ability. These services store data for as short a time as possible.

  • ● Cookie name
  • ● Cookie Expiry
Why do we store it?
  • ● tb_mkt
  • ● ThatVPN marketing
  • ● Session
  • ● ThatVPN records a bit of information that helps us track how people are finding ThatVPN.
  • ● tb_ref
  • ● ThatVPN marketing
  • ● Session

This cookie helps us understand which ThatVPN touchpoint (eg: website, email) led you to purchase ThatVPN.

  • ● tb_overlay
  • ● ThatVPN marketing
  • ● 1 day

This cookie lets us know if you've already acknowledged any overlays that we display for our marketing or outreach initiatives. It does not contain any personal information.

  • ● ac
  • ● ThatVPN marketing
  • ● 1 year

This cookie lets us know if you've already acknowledged our cookie banner. It saves your preferences so that the banner doesn't show up every time you visit the site.

  • ● TB_SESSION
  • ● ThatVPN website customization
  • ● 7 days

This cookie stores your account type and is used to customize your ThatVPN.com account. We set a cookie so we don't have to continue checking your account type in the database as you use the website.

  • ● PLAY_SESSION
  • ● ThatVPN authentication
  • ● 7 days

PLAY_SESSION is the authentication token for ThatVPN.com. It allows you to use your account without having to continuously login.

  • ● tb_user
  • ● ThatVPN authentication
  • ● 30 days

tb_user allows us to understand whether you are a new or returning visitor to our website. By setting this cookie, we're able to customize the content on our own without using any third party tools.

  • ● tb_user
  • ● ThatVPN authentication
  • ● 30 days
  • ● tb_user
  • ● ThatVPN authentication
  • ● 30 days
  • ● tb_user
  • ● ThatVPN authentication
  • ● 30 days
1.5 Cookies and Persistent Trackers

In building our website and apps, we have tried to limit the number of services with access to store cookies in your browser. There are currently three third-party services with this ability. These services store data for as short a time as possible.

  • ● Cookie name
  • ● Service
  • ● Cookie Expiry
1.6 Other Data ThatVPN Just does NOT Collect
ThatVPN explicitly does NOT collect, store or log the following data:
  • ● IP addresses visiting our website
  • ● IP addresses upon service connection
  • ● DNS Queries while connected
  • ● Any information about the applications, services or websites our users use while connected to our Service
Personal Data

Any Personal Data you provide to ThatVPN will be administered according to the following principles:

2.1 Accountability

Should you have any concerns about how your Personal Data is handled or questions about this Privacy Policy, feel free to contact us at privacy (at) ThatVPN.com

2.2 Disclosure of Personal Data to Third Parties

Except as described below, ThatVPN will NOT disclose any Personal Data to other commercial parties under any circumstance:

We may send data to third-party service providers who operate services that help us with: customer support; email; hosting, protecting, and securing the ThatVPN infrastructure; DDoS prevention; payment processing; as well as understanding website analytics, app analytics, account and payment related service usage.

In the event ThatVPN is served with a valid subpoena, warrant or other legal document and applicable law requires ThatVPN to comply, the extent of disclosure is limited to the Personal Data listed within this Privacy Notice.

As noted above, ThatVPN utilizes PCI-compliant third-party payment processors to collect your credit card and other billing information.

If our organization structure changes (e.g., we undergo a restructuring or are acquired), we may need to migrate your Personal Data to a third party related to a business transaction, but, we will ensure that such a third party has entered into an agreement under which the use of your Personal Data is only related to purposes necessary for the transaction.

ThatVPN does NOT store users' originating IP addresses when connected to our service and thus cannot identify users when provided IP addresses of our servers. Additionally, we cannot disclose information about the applications, services, or websites our users consume while connected to our Services; as ThatVPN does NOT store this information.

2.3 Consent and Legitimate Interest

When you sign up for our Service and provide us Personal Data, you allow us to process that information in accordance with this Privacy Policy. We rely on legitimate interest for marketing, research, and fraud prevention. We will obtain your consent where required by law.

You have the right to ask us not to contact you. To exercise your choices or ask questions about your Personal Data, please contact us by visiting our privacy center.

2.4 Limiting Collection

We take great care to not collect Personal Data indiscriminately and limit collection to the minimum necessary information required to operate our service. By limiting the collection of data, we help to protect the privacy and security of your Personal Data.

2.5 Limiting Use, Disclosure, and Retention

We will not use your Personal Data for any purpose that you have not consented to. ThatVPN will NOT sell or trade Personal Data for commercial purposes.

Only ThatVPN's employees with a business need to know or whose duties require, are granted access to our customers' Personal Data. All such employees will be required as a condition of employment to respect the confidentiality of our customers' Personal Data.

We store your Personal Data only as long as 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.

2.6 Accuracy

It is your responsibility to inform ThatVPN of any relevant changes in your Personal Data by updating your account information.

2.7 Safeguards

ThatVPN uses exceptionally strong safeguards to protect the privacy of all our records, including your Personal Data. We implement physical, business and technical security measures. These strong safeguards are designed to prevent unauthorized access, disclosure, loss, theft, copying, use or modification to your Personal Data.

2.8 Openness and Transparency

So that you can be confident that we are handling your Personal Data appropriately, we take extraordinary measures to document our policies and provide openness and transparency around the data we collect, why we collect it and how we handle it.

2.9 Individual Access

If at any time you have a question about our records containing your Personal Data, we will do our best to answer it. You have the right to be told about the kind of Personal Data we maintain and how it is used. Upon request, we will provide you with information regarding the existence, use and disclosure of your Personal Data.

2.10 Individual Access

If you are visiting from the European Union, please note that by providing your Personal Data, you consent to any transfer of your Personal Data to USA and processing of your Personal Data globally in accordance with this Policy.

2.11 Rights of Access, Rectification, Erasure, and Restriction

You have the right to inquire as to whether ThatVPN is Processing Personal Data about you, request access to Personal Data, and ask that we correct, amend or delete your Personal Data where it is inaccurate.

Visit ThatVPN's privacy center to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by ThatVPN.

To protect your privacy, ThatVPN 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.

ThatVPN makes good faith efforts to provide you with the ability to delete your Personal Data, however there may be circumstances in which ThatVPN 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 or if you are involved in litigation with us, we would be required to retain your personal data, which is limited to the fields we discuss above in 1.2, 1.3 and 1.4.

If ThatVPN 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, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact ThatVPN by email at privacy (at) ThatVPN.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Residents of California Your California Privacy Rights - Shine the Light Law

ThatVPN 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

If you are a resident of California, you may exercise your rights in Personal Data by visiting ThatVPN's privacy center to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by ThatVPN. For purposes of the California Consumer Privacy Act, ThatVPN does not "sell" your Personal Data.

Residents of Nevada

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

2.12 Changes to Our Privacy Policy

We may need to change our Privacy Policy from time-to-time and all updates will be posted online. Your continued use of our Services after the effective date of such changes constitutes your acceptance of such changes. We will post an effective date at the top of the page for your convenience.

We welcome your thoughts and feedback.