General Information KilikConnect may collect five (5) types of data depending on your use of the Services, as follows. You can find detailed information about each of them in the specific sections below. If you are just visiting our Site, please refer to Section 7. (i) Personal data submitted in association with your Account (“Personal Data”) Personal Data means any information that can be used, alone or combined with other data, to uniquely identify an individual. Personal Data is collected for the purpose of providing you with our Services, including preventing fraudulent signups or account hijacking, and may include the name, email address, and payment information that you submit to us when you create or update your Account. (ii) Aggregate Apps and VPN connection summary statistics (“Usage Statistics Data”) A minimal amount of Usage Statistics Data is collected in order to maintain excellent customer support and quality of service. This type of data does not include information about users’ browsing and internet activity, including while connected to the VPN—we do not collect (and therefore do not use, disclose, or store) data about the content or destinations of VPN traffic, DNS queries, or user IP addresses. (iii) Data added to KilikConnect Keys (“Keys Data”) (applicable only to KilikConnect Keys users) Keys Data refers to all the data stored within the KilikConnect Keys associated with your Account, which may include user logins and passwords to your services and accounts, as well as other types of data you choose to store. Keys Data is encrypted the moment you add it to KilikConnect Keys, and we are not capable of viewing, decrypting, or accessing Keys Data under any circumstance (even if you want us to). You may add, modify, and delete your Keys Data at any time by accessing your KilikConnect Keys dashboard. (iv) Anonymous App diagnostics, including crash reports (“App Diagnostic Data”) (optional) App Diagnostic Data, which includes crash reports, usability diagnostics, and VPN connection diagnostics, is anonymized data that cannot be tied back to individual users. This feature is similar to a “send bug report” option. App Diagnostic Data is not shared by default. You must opt in, such as through the settings menu of your Apps, to send App Diagnostic Data to us. (v) IP addresses authorized to use MediaStreamer Services (“MediaStreamer Data”) (applicable only to MediaStreamer users) Separately from VPN services, we also provide our optional MediaStreamer service for devices that do not support VPNs (e.g., Roku). Users who opt in to using MediaStreamer can choose to register specific IP addresses that should be authorized to use the service. These IP addresses are only used by KilikConnect to provide the optional MediaStreamer service and not for any other purpose. Personal Data KilikConnect collects Personal Data that you provide by creating or updating an Account. We require Personal Data, such as an email address and payment information, so that we can provide you with our Services, email you, collect payments and corresponding taxes, prevent fraud, respond to support queries, and share relevant information about your Account and/or the Services. Specific Personal Data collected will depend on the payment method you choose and may include information such as name, billing country, billing address, and/or credit card number. For some forms of payment, you may be redirected to external websites operated by third-party payment processors (e.g., PayPal, BitPay, Paymentwall, Stripe, or other specific payment processors, depending on your location) to complete the transaction. To understand what personal data these processors collect and store, please refer to the respective processor’s terms and privacy policy. Payment methods that help to minimize the amount of Personal Data you submit to us, such as Bitcoin, are also available for you to use to subscribe to our Services. In addition, we engage with trusted partners for the purposes of simplifying the login process, detecting fraudulent signups, and preventing account hijacking. These partners may obtain user IP addresses, but these addresses are always stored separately from systems unrelated to these purposes; can never be connected to the online behavior of any user, because no record of any such behavior is collected; and are always permanently deleted after 30 days. KilikConnect uses your email address for the following reasons: • To provide you with access to our Services, including through password reset or verification emails. • To send emails related to your payment transactions. • To send you updates and announcements. • To communicate with you about your Account or respond to your communications. • To send marketing information, such as offers, surveys, invitations, and content about other matters in connection with KilikConnect that we believe may be of interest to you (“Marketing Emails”). You may choose to not receive Marketing Emails by following the unsubscribe procedure described in these emails. KilikConnect uses your Personal Data only for the purposes listed in this Privacy Policy, and we do not sell or lease your Personal Data to third parties. We collect and process your Personal Data for legitimate interest under the applicable law, more specifically to fulfill our contractual obligations to you (i.e., according to the Agreement between you and KilikConnect). Any personal information associated with KilikConnect accounts is controlled only by KilikConnect, including being stored on systems, servers, and services owned or leased by KilikConnect and its subsidiaries. In the limited circumstances where this data may need to be processed by other related entities, it may be shared only when required, and for the duration required, for processing solely related to the purposes and legitimate interests outlined in this Privacy Policy, while ensuring at all times the same data protection standards. For avoidance of doubt, these circumstances do not include any situations where control of personal information of KilikConnect users will be transferred to any other related entities, including but not limited to our ultimate holding company, Kape Technologies PLC, for any duration of time. How We Protect and Retain Your Personal Data • Security. We have implemented best-in-class physical, procedural, and technical security measures with respect to our offices and information storage facilities so as to prevent any loss, misuse, or unauthorized access, disclosure, or modification of your Personal Data. Although we believe these systems are robust, it is important to understand that no data security measures in the world can offer completely infallible protection. For this reason, our guiding principle is to collect minimal data. • Servers and data centers. Servers are housed in data centers with strong security practices. None of these data centers require us to collect or store any traffic data or Personal Data related to your use of the Services. If any data center were to ask us to log such data, we would immediately cease operations with said service provider and find alternative options. Even if a government were to physically seize one of our VPN servers, there would be no logs or information that would tie any individual user to a particular event, website, or behavior. • Retention of your Personal Data. Your Personal Data—which, to reiterate, never includes any sensitive data such as browsing history, DNS queries, or IP addresses linked to that information or any other online behavior—is retained for a limited period in accordance with applicable data protection law (for as long as we have your consent or a legitimate reason for holding such data). You may request to have your data deleted by sending a valid deletion request (please see Section 11). Please note that if you request the deletion of your Personal Data, you will as a result no longer be able to use the Services. • Legal. Your Personal Data is controlled by and stored under KilikConnect, and not by its ultimate holding company, Kape Technologies PLC (UK) or other related entities. KilikConnect Technologies Ltd. operates under BVI jurisdiction, in accordance with BVI laws (pursuant to Section 16 of the Terms). Consequently, any demand via legal means for Personal Data (or other types of data) is subject to BVI jurisdiction and laws. We fight vigorously to defend our rights (and those of our users) if an attempt is made to bypass the privacy protections provided for by the BVI. A parent, subsidiary, or related entity cannot be compelled to, nor would it voluntarily, provide Personal Data stored by KilikConnect Technologies Ltd. To learn more about how we protect your privacy and security, visit the KilikConnect Trust Center. How We Safeguard Your Personal Data With Relation to Service Providers Agents, contractors, and third-party service providers of KilikConnect (“Service Providers”) may have controlled access to relevant data to help us process payments, administer the Services, and otherwise assist us in operating our business. All Service Providers who may gain access to such data have confidentiality and data processing obligations to keep the data confidential and not use them for any other purpose than to carry out the services they are performing on behalf of KilikConnect. These obligations include contractual commitments to protect data as required by applicable laws, including those covering the transfer of Personal Data from the European Union / European Economic Area to a third country. Service Providers only have access to the data necessary for the services they are performing on behalf of KilikConnect, which in any case will never include VPN activity or connection data as we do not collect such data. In addition to Service Providers, we may share your Personal Data where you have provided your consent to us for sharing or transferring your Personal Data (e.g., marketing consents or opt-in to optional additional services or functionality). Keys Data We collect and store Keys Data only if you choose to use KilikConnect Keys, the password and secure data manager service accessible via your Account. Keys Data stored in KilikConnect Keys is secured with zero-knowledge encryption. No KilikConnect staff or Service Providers can view or retrieve the information you store in KilikConnect Keys (not even if you authorize us to KilikConnect so). Your Keys Data is your property. You may add, modify, and delete Keys Data at your discretion by accessing your KilikConnect Keys’ dashboard. For your protection, you should create a strong and unique primary password for KilikConnect Keys to ensure that it is not easily guessed. It should also be different from the password used to access your Account. You can import data from other password management tools into KilikConnect Keys by following the instructions in your Account. Before doing so, we strongly suggest that you review the data portability rules of your former password manager provider, as these are not under KilikConnect control. Usage Statistics Data and App Diagnostic Data In order to maintain excellent customer support and quality of service, KilikConnect collects certain information related to your VPN usage, as described below. The data we collect for this purpose is visible to our staff strictly on a need-to-know basis, and may be shared with Service Providers for the purposes above, but is kept confidential at all times. We ensure that Usage Statistics Data and App Diagnostic Data never include any sensitive information, in line with our overall commitment to never logging browsing history, traffic destination, data content, IP addresses, or DNS queries. With regard to VPN Usage Statistics, our principle of minimal data collection means that: • We do not know which user ever accessed a particular website or service. • We do not know which user was connected to the VPN at a specific time or which VPN server IP addresses they used. • We do not know the set of original IP addresses of any given user’s computer. Should anyone try to compel KilikConnect to release user information based on any of the above, we cannot supply this information because the data does not exist. Apps and Apps versions We collect information related to which Apps and Apps version(s) you have activated in order to use our Services. Knowing your current version of the Apps allows our Support Team to troubleshoot technical issues you may encounter. Successful connection As you use the App, we collect information about whether you have successfully established a VPN connection on a particular day (but not a specific time of the day), to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address). This minimal information assists us in providing technical support, such as identifying connection problems, providing country-specific advice about how to best use our Services, and enabling KilikConnect engineers to identify and fix network issues. Aggregate sum of data transferred (in MB) We collect information regarding the total sum of data transferred by a given user. Although we provide unlimited data transfer, if we notice that a single user pushes more traffic than thousands of others combined, thereby affecting the quality of Services for other KilikConnect users, we may contact that user for an explanation. Usage Statistics Data summary In summary, we collect minimal usage statistics to maintain our quality of service. We may know, for example, that our customer John had connected to our New York VPN location on Tuesday and transferred an aggregate of 823 MB of data across a 24-hour period. John can’t be uniquely identified as responsible for any specific online behavior because his usage pattern overlaps with thousands of other KilikConnect customers who also connected to the same location on the same day. We’ve engineered our systems to categorically eliminate storage of sensitive data. We may know THAT a user has used KilikConnect, but we are unable to single out the user and we never know HOW they have utilized our Service. We stand by our firm commitment to our users’ privacy by not possessing any data related to a user’s online activities. App Diagnostic Data With your opt-in permission, we collect anonymized App Diagnostic Data, which includes crash reports, usability diagnostics, and VPN connection diagnostics. We use this data in our network operations tools to help optimize network speeds and to let us identify problems and areas for improvement related to specific apps, VPN servers, or internet service providers (ISPs). This App Diagnostic Data we receive is fully anonymized and cannot be tied back to individual users (i.e., we do not store which user sent which data, and we do not store user IP addresses). If you opt in to share this information with KilikConnect (in the settings menu of your Account), we will collect the following anonymized App Diagnostics Data: • Diagnostic information about if and how a VPN connection attempt failed. • Speed test data. • App diagnostics, including crash reports and usability diagnostics, without any personally identifiable information. These are handled in an anonymized form by the following Service Providers bound by non-disclosure and other contractual obligations, dependent on the platform you are using KilikConnect on: • Windows: Sentry, owned by Functional Software, Inc. See Sentry’s Privacy Policy. • Mac: Firebase Crashlytics, owned by Google, and Sentry, owned by Functional Software, Inc. See Firebase’s Privacy and Security documentation and Sentry’s Privacy Policy. • Linux: Sentry, owned by Functional Software, Inc. See Sentry’s Privacy Policy. • iOS: Firebase Crashlytics, owned by Google, and Apple. See Apple’s Privacy Policy and Firebase’s Privacy and Security documentation. You can disable Apple’s crash reporting in iOS settings as described here. • Android: Firebase Crashlytics, owned by Google. See Firebase’s Privacy and Security documentation. • Browser extensions: Google Analytics, owned by Google. See Google’s Privacy Policy. Upon activation of any of our Apps, you will be asked if you would like to share App Diagnostics Data with KilikConnect. You can start or stop sharing this data at any time in your App’s settings menu. On iOS, Apple’s crash reporting can be turned off in iOS settings. MediaStreamer Data MediaStreamer is our service for consoles and other devices that don’t support running a VPN (e.g., Roku). Because the service doesn’t run on an app and doesn’t have an option for username/password authorization, we rely on a system that authorizes specific IP addresses that you have chosen to register with us. You can register IP addresses by logging in to our Site and using the “DNS Settings” page. Those IP addresses (the MediaStreamer Data) are then stored in our system in order to identify authorized devices for MediaStreamer and are not used for any other purpose. If you do not wish to use our MediaStreamer service but have devices that cannot run a VPN, we suggest using the KilikConnect App for routers. Like all of our Services outside of MediaStreamer, the App for routers does not require IP address registration. Please contact us at support@KilikConnect.com, and we will guide you through the steps. How We Protect and Retain Information Related to Email, Live Chat, and Feedback Forms KilikConnect keeps records of any correspondence, questions, complaints, or compliments you submit to us through our Site or Services, along with our response. Depending on how you contact KilikConnect, we may collect your email address and any additional information you provide to us. Having full correspondence records enables our staff to provide the best possible customer support experience. We use two different third-party platforms for support correspondence: Zendesk for emails and support tickets and TeamSupport for live chat. When you correspond with us using these platforms, they will store your correspondence records—including your email address, as well as user and device attributes that help with troubleshooting, such as the country you are contacting us from and your device’s operating system. Both platforms utilize modern security practices and SSL encryption. See Zendesk’s Privacy Notice and TeamSupport’s Privacy Policy. Cookies and Third-Party Analytics For user experience and analytics purposes, KilikConnect uses several analytics services, including from third-party Service Providers. These services may use cookies, mobile identifiers, and other data to generate reports and statistics, but have no access to information that directly identifies individuals nor any Personal Data that users provide to KilikConnect. What is a Cookie? Cookies and other similar technologies are small text files used to store information about your visit to the Site on your computer or mobile device (“Cookies”). Cookies allow websites to “remember” your actions or preferences over time, which allows us to optimize and improve the user experience of the Site by helping us deliver certain functionalities, such as website login and language settings. The Cookies we use may vary over time as we continuously update and improve our Site. Disabling Cookies When you visit the Site for the first time, you will be invited to set your Cookie preferences. You can also change these preferences at any time by selecting Cookie Preferences from the menu at the bottom of most pages on the Site. Alternatively, you may be able to change your Cookie preferences from the settings panel of your browser. Note that our Site may not work as intended if you choose to disable Cookies. KilikConnect Cookies The Cookies set by KilikConnect enable us to set your language preference, attribute visitors to a marketing channel, and, once you log in, securely show you information that is specific to your Account. The Cookies contain a user identifier, but no directly personally identifying information such as your name or email address and do not track any activity outside of KilikConnect KilikConnect VPN’s domains. Third-Party Cookies KilikConnect uses Cookies from third-party services for Essential, Functional, and Marketing purposes. Cookies that are necessary for the proper functioning and optimization of the Site are known as Essential Cookies. For example, we use PayPal to allow users to make payments via that service. Other Essential Cookies in use include those that allow payments via Forter, Braintree, and Chargebee; those that allow us to analyze and improve page performance, including Google Analytics, Google Optimize, Visual Website Optimizer, and Google Tag Manager; those that allow us to manage traffic, deliver content, and combat malicious bots, including Cloudflare, Cloudfront, and Gstatic; and one that allows you to specify your Cookie preferences, Usercentrics Consent Management Platform. Essential Cookies cannot be disabled, and by using the Site, you are consenting to them. Cookies that enable us to properly display or manage elements on the Site are known as Functional Cookies. For example, we use Google Fonts to properly display text. Other Functional Cookies in use include those for displaying video, including YouTube Video and Vzaar; those that produce maps, including OpenStreetMap and Google Maps; those used in managing Cookies, including Google Ajax and jQuery; one for tracking and reporting errors, Sentry; one for displaying avatars, Gravatar; and one for presenting quizzes and questionnaires, Typeform. Functional Cookies can be disabled. Cookies that are used by advertisers to serve ads that are relevant to your interests are known as Marketing Cookies. For example, we use Google Ads remarketing to show advertisements on third-party websites (including Google) to users who have visited our Site. We may show such users advertisements on a Google search results page or on a site in the Google Display Network. Other Marketing Cookies in use include those from DoubleClick Ad, Facebook Pixel, Facebook Social Plugins, Google AdServices, Google Syndication, Microsoft Advertising Remarketing, and PayPal Marketing Solutions. Marketing Cookies can be disabled. Service Providers, including Google, use Cookies to serve ads based on someone’s past visits to the Site. Any data collected will be used in accordance with our Privacy Policy and Google’s privacy policy. In addition to setting Cookie preferences via your browser or the menu at the bottom of our Site, users also may opt out of Google’s use of Cookies by visiting the Google Advertising Opt-out Page. Users may opt out of Google Analytics by visiting the Google Analytics Opt-out Page. Users may opt out of third-party use of cookies by visiting the Network Advertising Initiative Opt-out Page. Device information KilikConnect uses device information (including device type, operating system/language, or user agent, as well as mobile identifiers provided by Android or iOS devices) to generate statistics related to the marketing channels and advertising partners through which users learned about and signed up for KilikConnect Apps. This device information does not contain your name, email address, or other Personal Data. Disabling or resetting mobile identifiers Users may disable or reset the mobile identifiers associated with their devices at any time. For instructions, see Apple’s page on Advertising & Privacy on iOS devices and Google’s page on Managing your Google Settings on your Android device. Email/communication analytics To assess and improve the emails and other communications we send, KilikConnect or its Service Providers may collect data for statistical reports. For example, we may generate reports assessing whether emails were successfully sent, whether there were any delivery delays, or the number of times an email was opened. Interactions With Third-Party Products The Site may contain links to external websites, mobile software applications, products, or services that are not owned or controlled by KilikConnect, and may be subject to specific terms and conditions. Please be aware that such third parties may collect personal information from you. KilikConnect is not responsible for the privacy practices or the content of such external websites. We encourage you to read the terms and conditions and privacy policies of each third-party service provider you engage in connection with the Site or the Services. Users in the European Union KilikConnect 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 Data. 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 Personal Data outlined in this Privacy Policy on one of the following bases, depending on the circumstances: • For the purposes of fulfilling our contractual obligations, including: • Providing Subscribers with the Services they have requested. • Managing subscriptions and processing payments in connection with our Services. • Providing customer support. • For a legitimate interest associated with the operation of our business, including: • Enhancing the quality, reliability, and effectiveness of our Services. • Communicating with customers to provide information and seek feedback related to our Services. • With the consent of users, which users can withdraw at any time. Your Privacy Rights • Rights: In using our Services, you have the following rights (subject to certain exceptions or exemptions). • You have a right to access personal data held about you. • You have the right to request that we rectify any personal data we hold that is inaccurate or incomplete. • You have the right to request the deletion of your personal data. Please note that such deletion may result in us no longer being able to provide you with our Services. • You have the right to request restriction of or object to the processing of your personal data. • You have the right to request and receive your personal data in a commonly used format (data portability). • You have the right to withdraw your consent on which processing is based at any time. • You have a right to complain to your local data protection supervisory authority. • You can exercise your rights above by contacting us as described in Section 16. • You may have a third party submit a request on your behalf as an authorized agent. To confirm that the authorized agent is entitled to submit a request on your behalf, they must have written authorization signed by you, and you must provide us with a copy of the signed authorization. To ensure your privacy and security, we may take further steps to verify your identity. • We will address any requests in accordance with applicable laws and to the best of our ability in a timely manner. Users in California • Under the “Shine the Light Act” (California Civil Code Section 1798.83), California residents may request information about any disclosure of personal data to third parties for their direct marketing purposes. We do not disclose any such data to third parties for direct marketing. Nonetheless, California residents who wish to make a request (once per user per year) may contact us as described in Section 16. • The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals covered by the California Consumer Privacy Act (“CCPA”): • You have the right to know what personal data is being collected about you and how it is used and shared. • You have the right to request the deletion of your personal data. Please note that such deletion may result in us no longer being able to provide you with our Services. • You have the right to opt out of the sale of your personal data. However, there is no need to exercise this right as KilikConnect does not sell any data to third parties. • You have the right not to be discriminated against for exercising any of these rights or other rights under the CCPA. • You have the right to withdraw your consent on which processing is based at any time. Use by Children We do not offer our Services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about individuals under the age of eighteen (18) or under the age of majority in the jurisdiction of residency / from which the Services are used. If you are under the age of eighteen (18), or under the age of majority in the jurisdiction where you reside or from which you use the Services, do not provide any Personal Data to us without the involvement of a parent or a legal guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us as described in Section 16. Changes to This Privacy Policy We may change our Privacy Policy from time to time, with or without notice to you, consistent with applicable privacy laws and principles. Your continued use of the Services and/or access to the Site constitutes your acceptance of our Privacy Policy